THE U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 


PUBLIC HEALTH SERVICE 


CENTERS FOR DISEASE CONTROL AND PREVENTION 


NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH 


convenes the 


WORKING GROUP MEETING 


ADVISORY BOARD ON 


RADIATION AND WORKER HEALTH 


ROCKY FLATS
 

The verbatim transcript of the Working 


Group Meeting of the Advisory Board on Radiation and 


Worker Health held in Hebron, Kentucky on January 


26, 2007. 

2 

 6 

C O N T E N T S
 

January 26, 2007 


WELCOME AND OPENING COMMENTS 


DR. LEWIS WADE, DFO 


COMPLETENESS OF DATA 18 


1969 DATA GAP 71 


COWORKER MODELS 119 


OTHER RADIONUCLIDES - THORIUM 142 


LOG BOOK ANALYSIS AND DATA INTEGRITY 195 


SAFETY REPORTS 195 


SUPER S (TIB 49) 241 


NEUTRON ITEMS 254 


D AND D (TIB 0014) 259 


MATRIX UPDATE 261 


COURT REPORTER’S CERTIFICATE 274 

3 

TRANSCRIPT LEGEND
 

The following transcript contains quoted material. Such 


material is reproduced as read or spoken. 


In the following transcript: a dash (--) indicates 


an unintentional or purposeful interruption of a 


sentence. An ellipsis (. . .) indicates halting speech 


or an unfinished sentence in dialogue or omission(s) of 


word(s) when reading written material. 


-- (sic) denotes an incorrect usage or pronunciation 


of a word which is transcribed in its original form as 


reported. 


-- (phonetically) indicates a phonetic spelling of 


the word if no confirmation of the correct spelling is 


available. 


-- "uh-huh" represents an affirmative response, and 


"uh-uh" represents a negative response. 


-- "*" denotes a spelling based on phonetics, 


without reference available. 


-- (inaudible)/ (unintelligible) signifies speaker 


failure, usually failure to use a microphone. 

 

 

 

4

 P A R T I C I P A N T S 


(By Group, in Alphabetical Order) 


BOARD MEMBERS
 

EXECUTIVE SECRETARY
 

WADE, Lewis, Ph.D. 


Senior Science Advisor 


National Institute for Occupational Safety and Health 


Centers for Disease Control and Prevention 


Washington, DC 


MEMBERSHIP
 

GIBSON, Michael H. 


President 


Paper, Allied-Industrial, Chemical, and Energy Union 


Local 5-4200 


Miamisburg, Ohio 


GRIFFON, Mark A. 


President 


Creative Pollution Solutions, Inc. 


Salem, New Hampshire 


MUNN, Wanda I. 


Senior Nuclear Engineer (Retired) 


Richland, Washington 


PRESLEY, Robert W. 


Special Projects Engineer 


BWXT Y12 National Security Complex 


Clinton, Tennessee 

5 

IDENTIFIED PARTICIPANTS
 

ALBERG, JEANETTE, SEN. ALLARD 


BARKER, KAY, ANWAG 


BARRIE, TERRY, ANWAG 


BOLLER, CAROLYN, CONG. UDALL 


BRACKETT, LIZ, ORAU 


BROEHM, JASON, CDC WASHINGTON 


BUCHANAN, RON, SC&A 


CHANG, CHIA-CHIA, NIOSH 


DEMAIORI, TONY, PETITIONER 


ELLIOTT, LARRY, NIOSH 


ESCOBAR, FELICIA, SEN. SALAZAR 


FITZGERALD, JOE, SC&A 


HOFF, JENNIFER, ORAU 


HOMOKI-TITUS, LIZ, HHS 


HOWELL, EMILY, HHS 


JESSEN, KARIN, ORAUT 


KOTSCH, JEFF, DOL 


LABONE, TOM, ORAU 


LITTLE, CRAIG, ORAU 


LOPEZ, TERESA, ORAU 


MAKHIJANI, ARJUN, SC&A 


MAURO, JOHN, SC&A 


MEYER, BOB, ORAU 


NETON, JIM, NIOSH 


RICH, BRYCE, ORAU 


ROBERTSON-DEMERS, KATHY, SC&A 


SHARFI, MUTTY, ORAU 


SMITH, MATTHEW, ORAU 


THOMAS, ELYSE, ORAU 


ULSH, BRANT, NIOSH 

 

 

6 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

P R O C E E D I N G S


 (10:00 a.m.) 

WELCOME AND OPENING COMMENTS
 

DR. LEWIS WADE, DFO
 

DR. WADE: (by Telephone): Ray, are you up 


and running? 


 COURT REPORTER: Yes, sir, ready. 


 DR. WADE: (by Telephone): What this is is 


a meeting of the work group on Rocky Flats 


site profile and SEC petition activities that 


functions under the Advisory Board on 


Radiation and Worker Health. The group is 


most ably chaired by Mark Griffon, members 


Gibson, Presley and Munn. Also, the materials 


we’ve been providing, the principal NIOSH 


contact is identified as Brant Ulsh, and the 


principal SC&A contact identified as Joe 


Fitzgerald. 


Just for a little bit of background, 


the full Board at its last meeting decided 


that it stated its intentions to take up the 


Rocky Flats’ petition at its meeting in May, 


May 2, 3 and 4, later this year. It did that 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

7 

because of input it has had from petitioners 


and members of Congress and others as to the 


need to do a complete job in terms of the 


science issues that were remaining. So that’s 


the target for the Board, taking up the 


petition in earnest May, 2, 3 and 4. Our 


intention would be to do that in Denver, 


Colorado. 


Again, this is Lew Wade. I have the 


privilege of serving as the Designated Federal 


Official for the Advisory Board. I apologize 


for not being there. This is the first 


meeting of any type that I’ve not been able to 


be there face to face. So I’ll do my 


introductions, and I’ll be on the phone with 


you until noon. 


And then ably Chia-Chia Chang is 


there, and Emily Howell is there, and they’ll 


serve the role as Designated Federal Official 


as well as representing the Office of General 


Counsel. To them I’ll say I’ll have my cell 


with me and would be available on cell if you 


were to need me at any time during the course 


of the meeting. 


I first would like to establish what 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

8 

Board members are involved and present on the 


call. Mark, I assume you’re there. I’ve 


heard Wanda. I’ve heard Robert. Is Mike 


Gibson there as well? 


MR. GIBSON (by Telephone): I’m via phone 


call. 


DR. WADE (by Telephone): Okay, are there 


any other Board members that are either in the 


room that I didn’t identify or on the phone? 


 (no response) 


DR. WADE (by Telephone): So my hearing is 


that we have Mark, Wanda, Robert and Mike 


participating. We don’t have a quorum, and 


therefore, we can proceed. 


One quick news update, as many of you 


know, two new Board members have been 


identified, and it’s looking very likely that 


they would be seated at the table for our 


February meeting. It’s not completely done 


yet, but it’s certainly looking that way. And 


that’s good news for all of us, particularly 


the overworked Board members who they’ll be 


joining. 


One quick thing on phone etiquette, if 


you are participating by phone, please mute 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

9 

when you’re not talking. If you are talking 


use a handset. Realize that background noises 


of all types enter into the room and can 


distract the participants. And also, if you 


have a system where when you go on hold or go 


away for awhile and background music plays, 


please be aware of that and don’t do that to 


the working group. It happens more frequently 


than we would like. 


One other caution is with regard to 


the discussion of Privacy Act related 


information. This working group and those 


that support it have done a wonderful job of 


getting their documents in and cleared, and I 


think we have cleared documents available for 


anybody who would want them. But since this 


work group has in some of its deliberations 


got to look at individual records, I would 


just caution all of us in our discussions to 


be sure that we don’t get into anything that 


would contain personal identifiers or allow an 


individual to be identified. I think the 


documents are good. Just exercise a little 


discipline in your verbal comments as well, 


realizing that protecting everyone’s privacy 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

10 

is terribly important to all of us. 


I guess with that I would suggest that 


we go around the table and do our 


introductions. Please for ORAU/NIOSH team 


members and SC&A team members, when you make 


your introductions, please identify any 


conflicts you have with regard to this site. 


So I would start in the room from Mark’s 


right. 


MS. MUNN: This is Wanda Munn. I have no 


conflicts with Rocky Flats. 


MR. DeMAIORI: Tony DeMaiori, petitioner. 


DR. NETON: This is Jim Neton, NIOSH, I have 


no conflict at Rocky Flats. 


MR. PRESLEY: Robert Presley, Board member, 


I have no conflicts with Rocky. 


MR. SHARFI: Mutty Sharfi, ORAU team, no 


conflicts Rocky Flats. 


MS. CHANG: Chia-Chia Chang, NIOSH, no 


conflicts. 


MR. FITZGERALD: Joe Fitzgerald, SC&A, no 


conflict. 


DR. MAKHIJANI: Arjun Makhijani, SC&A, no 


conflicts.


 MS. JESSEN: Karin Jessen, ORAU team, no 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

11 

personal conflicts. 


MS. HOFF: Jennifer Hoff, ORAU team, no 


personal conflicts. 


DR. ULSH: Brant Ulsh with NIOSH, no 


conflicts. 


MR. LITTLE: Craig Little, ORAU team, no 


conflicts. 


MR. MEYER: Bob Meyer, ORAU team, no 


conflicts. 


MR. RICH: Bryce Rich, O-R-A-U team, have 


two year administrative oversight conflicts. 


MR. ELLIOTT: Hello, this is Larry Elliott, 


no conflicts. 


MS. HOWELL: Emily Howell, HHS, no 


conflicts. 


MR. GRIFFON: And Mark Griffon with the 


Advisory Board, no conflicts. 


And Lew, we’ll go back to the phone 


people. 


DR. WADE (by Telephone): If there’s any 


NIOSH/ORAU team or SC&A team members on the 


line, please identify yourself. 


MR. SMITH (by Telephone): Yeah, this is 


Matthew Smith, ORAU team, no conflicts. 


MS. BRACKETT (by Telephone): Liz Brackett, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

12 

O-R-A-U team, no conflicts. 


DR. WADE (by Telephone): SC&A? 


DR. MAURO (by Telephone): John Mauro, SC&A, 


no conflicts. 


MR. BUCHANAN (by Telephone): This is Ron 


Buchanan, SC&A, no conflicts. 


MS. LOPEZ (by Telephone): Teresa Lopez, 


ORAU team, no conflicts. 


DR. WADE (by Telephone): Any other team 


members, SC&A, ORAU/NIOSH? 


MR. LaBONE (by Telephone): I’m sorry, this 


is Tom LaBone, O-R-A-U team, no conflicts. 


MS. DeMERS (by Telephone): This is Kathy 


Robertson-DeMers, SC&A, no conflicts. 


MS. THOMAS (by Telephone): This is Elyse 


Thomas, O-R-A-U team, no personal conflicts. 


DR. WADE (by Telephone): Anyone else? 


MR. GIBSON (by Telephone): Lew, this is 


Mike down at the complex. 


DR. WADE (by Telephone): Welcome. 


Any other federal employees who are on 


the line by virtue of their federal 


employment? 


MS. BOLLER (by Telephone): This is Carolyn 


Boller with Congressman Mark Udall’s office. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

13 

DR. WADE (by Telephone): Welcome. 


MS. ALBERG (by Telephone): And Jeanette 


Alberg with Senator Allard’s office. 


DR. WADE (by Telephone): Welcome. 


MS. ESCOBAR: And this is Felicia Escobar 


with Senator Ken Salazar’s office. 


DR. WADE (by Telephone): Welcome all. 


MS. HOMOKI-TITUS (by Telephone): Liz 


Homoki-Titus with Health and Human Services, 


and I have no conflicts. 


DR. WADE (by Telephone): Jeff? 


MR. KOTSCH (by Telephone): Jeff Kotsch with 

Department of Labor. 

MR. BROEHM (by Telephone): Jason Broehm, 

CDC Washington Office, no conflicts. 


DR. WADE (by Telephone): Anyone else who 


would like to be identified, petitioners, 


representatives, workers at the site? Anyone 


else who would like to be identified for the 


record? 


MS. BARRIE: Terry Barrie with ANWAG. 


DR. WADE (by Telephone): Thank you for 


being with us, Terry. 


MS. BARRIE: Kay Barker will be on the line 


later. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

14 

DR. WADE (by Telephone): She’s more than 


welcome. 


Okay, Mark, I think it’s all yours. 


MR. GRIFFON: Before we start I think Emily 


wanted to take the floor for a second. 


MS. HOWELL: I just wanted to kind of 


reiterate what Lew was saying a minute ago 


about Privacy Act protected information. I 


think that we work really hard to try and 


review all of the documents for these 


meetings, but this working group has in its 


quest to really delve into information has 


gone to the level of looking at individual 


files. 


And I think that there’s some older 


versions of the matrix that are out there 


floating around that may include some 


protected information. As members of the 


working group or our contractors you’re able 


to have those. 


But please just be aware that you may 


have a version if it was, if you printed it or 


received it prior to yesterday afternoon then 


the version you have probably does have 


protected information in it, and I think that 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

15 

Brant has some redacted matrices if you would 


like a new copy. So please just be aware of 


that if you go to speak off of the matrix. 


If there’s a name in it, and it’s not 


someone who’s sitting around this table as an 


OCAS, ORAU or SC&A employee, you probably 


should not be saying that name. And if you 


ever have any questions, you’re more than, I’m 


more than willing to take any questions at any 


time. 


MR. GRIFFON: I think we’ve been, I mean I 


think we can work with that with the work 


group here today. The only person I have, I 


think the prior matrices have been made public 


in the Board meetings so they’re out there, 


not just internally circulated within the work 


group. 


MS. HOWELL: Right, and like I said, this is 


kind of a continuing area of concern, and 


we’re trying to work on this, but there may be 


other matrices that include information that 


we would have liked redacted that are still 


out in the public so we’re just trying to get 


better from here on out. 


DR. MAKHIJANI: Could I ask a question? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

16 

MS. HOWELL: And if you do have copies of 


the old matrices that have the Privacy Act 


protected information in them or if you’re not 


sure, if you could discard them and do so in a 


careful manner, that would be helpful. 


Arjun? 


DR. MAKHIJANI: Yeah, could I ask a question 


about that? Now there is one individual I 


know who NIOSH asked for Privacy Act release, 


and he did sign an appropriate form --


MS. HOWELL: Okay, I would prefer you talk 


about that off line with me. Without having 


it in front of me I can’t be sure, and any 


time we get into these discussions around the 


table, we could be making the problem worse. 


So we can talk about that during the break. 


DR. MAKHIJANI: All right. 


MR. GRIFFON: I don’t think this in any way 


affects what we have to discuss here in this 


meeting, but we should all understand the 


rules so let’s just, we can work from the 


redacted version of the matrix today. 


Actually, I have an abbreviated agenda 


which we’ve been using for most of the last 


two or three work group meetings. And then 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

17 

I’d like to use that same sort of format, 


cover the main action items of interest and 


then go back through this redacted matrix 


toward the end of this meeting and make sure 


we’ve captured everything and sort of update 


ourselves. 


The agenda I’d propose, and partly 


this was to frontload the items I thought were 


the most pressing and also to allow some SC&A 


personnel to be online when they need to be 


and not necessarily for the whole day and the 


same goes for some ORAU people maybe. 


I’d like to start off with number one, 


data completeness; number two, the ’69 data 


question; number three is the coworker models, 


and that’s mainly as they pertain to this 


question of completeness. Number four is 


other radionuclides, and I think we’re down to 


thorium as our other radionuclide outstanding 


action here. Number five is log book 


analysis; six is the safety report analysis. 


Seven is the Super S item; eight is neutron 


issues, and nine is D and D worker questions. 


So if that’s okay with everyone, I’ll 


think we’ll stick to that. I tried to, like I 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

18 

said, frontload some of the more, items I 


thought were going to take a little longer and 


were maybe more pressing. Any comments on 


that; otherwise we’ll proceed. 


COMPLETENESS OF DATA
 

All right, let’s start off with the 


data completeness. I think where we stand on 


this is that SC&A provided a report, and did 


we get the whole report or were there still 


pieces that were Privacy Act review or at this 


point we have the whole section of the report? 


MR. FITZGERALD: Yeah, the whole section of 


the report has gone through Privacy Act 


clearance and was distributed on January 10th
 

to the working group. So it’s been through 


all the review. 


MR. GRIFFON: Can I ask NIOSH is that 


distributed to petitioners and other 


interested parties? It went through Privacy 


Act review. I thought we were going to try to 


get those components out. 


Lew, do you know if that was made 


available to the petitioners and other 


interested --


MS. BARRIE: Mark, this is Terry Barrie and 

1 

2 

3 

4 

5 

6 

7 

8 

9 -- 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

19 

no, I have not received any reports that have 


been cleared by the Privacy Act. 


DR. WADE (by Telephone): I guess I would 


ask, Larry, if you would make a note to see 


that that’s distributed. 


MR. ELLIOTT: Yes, I will. 


MR. GRIFFON: I think we agreed that this 


was okay, right? These draft sections of the 


DR. WADE (by Telephone): Yes, once they’ve 


been cleared, yes. 


MR. GRIFFON: So I think there’s a couple --


MR. ELLIOTT: I just don’t know that I’ve 


had approval that they’ve cleared. Well, 


we’ll check into it. 


MR. GRIFFON: Once we’re sure they’ve been 


Privacy Act reviewed and cleared, we’ll get 


those distributed as soon as possible, right? 


MR. ELLIOTT: Yes, as soon as I hear that 


they’re approved for distribution, we’ll put 


them on the website and we’ll share it with 


the petitioners and interested external 


parties. 


MR. GRIFFON: I didn’t know that it had to 


be on the website, but --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

20 

DR. MAKHIJANI: Yeah, what didn’t happen is 


we sent the materials to CDC to Emily, and we 


got instructions about what to take out that 


was covered by the Privacy Act, and we did 


that. And then put together a version that 


was completely de-identified as per the 


instructions. And that’s what --


MR. FITZGERALD: That’s what on January 10th , 


at least for this particular section, we 


transmitted to NIOSH and the work group. 


That’s as far as it went. It went to the work 


group as well as NIOSH, and with a notation 


and a cover e-mail that we would assume that 


NIOSH would handle outside distribution. 


MR. GRIFFON: Okay, that’s fine. Larry, you 


can check on making sure that it’s been 


finally approved for distribution. I think 


the way, part of the reasoning here is that 


these are draft sections, final draft sections 


of SC&A’s overall report, and we kind of, the 


notion was to keep the petitioners and other 


interested parties informed along the way 


instead of dropping one big report at the end 


of --


MR. ELLIOTT: I understand. I share the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

21 

interest in making that happen. I can’t do it 


until I hear I’m okay to do it. 


MR. GRIFFON: With that maybe we’ll just 


start, Joe, if I can, I’ll give you the floor 


to give us an overview of what you’ve put in 


this report. 


MR. FITZGERALD: On this particular issue we 


caught in shorthand the completeness issue but 


again, we’re going back to an old issue in a 


sense because when we reviewed the Rocky 


Flats’ site profile, we did spend quite a bit 


of time focusing on concerns, certainly 


concerns expressed by the former workers that 


there were unexplained zeros, perhaps gaps in 


records, notations, such as no data available. 


So we certainly raised those questions 


in the site profile and certainly the 


petitioners have raised similar issues in the 


petition. So certainly going into this 


evaluation we wanted to focus on that from a 


number of different vantage points. And we 


spent a great deal of time on the data 


reliability side looking at whether or not we 


could corroborate that question by virtue of 


the log book reviews that we’ve done, and 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

22 

we’ll talk about that later, evaluating quite 


a few safety concerns that were available and 


also looking at certain, the affidavits and 


certain data integrity issues. 


On this particular issue though we 


were also concerned about looking at the 


database as a whole. Looking at whether or 


not one could look at the database and 


ascertain how complete in fact it is. We 


looked at HIS-20, which is the electronic 


database, first. And in our comparative 


reviews we certainly began picking up some 


issues, some discrepancies. 


It took some time, I think, to get 


into a level of understanding as to what we 


were looking at. But over the course, I 


think, of middle and last, late last year we 


certainly established that we had a number of 


issues regarding the completeness of the 


electronic database, HIS-20. 


Certainly, at that stage we turned to 


the, what we would call, the claimant file, 


the raw data itself that the HIS-20 is based 


on, certainly wanting to know how complete 


that is in fact because that would be, in 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

23 

fact, the original data that would be the 


baseline for doing dose estimations. 


We did a sampling analysis initially 


which was basically just doing a limited 


number of samples, in this case a dozen, just 


to get some sense of what we were looking at. 


That sort of reconnaissance survey 


demonstrated a number of gaps that we were, I 


think, taken aback by. We didn’t expect to 


see in that kind of a limited sample the kinds 


of gaps that we did see. 


That led to our going to this working 


group, and certainly looking for their 


guidance which they suggested that we expand 


that sampling to include what ended up being 


40 more cases from the original raw data file. 


So this is a total now of 52 cases that we 


were sampling out of the original claimant 


file. And that sampling plan was designed to 


be, given the sample size, as representative 


as we could be. 


And so in any case the analysis that 


we presented right after New Year’s is in 


essence our report of what that sampling of 


the 52 cases showed us. And quite frankly, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

24 

and I’m going to turn to Arjun in a second to 


walk through the details, the bottom line, it 


corroborated, I think, our initial concerns on 


that smaller sample that there are, in fact, 


are significant gaps in the claimant file upon 


which your coworker models and other 


estimations would be based. 


So we do have serious concerns over 


whether or not this database is going to be 


sufficiently complete to do coworker modeling 


and to do the necessarily gap filling that one 


has to do when you have unmonitored workers. 


So with sort of a prelude and background I 


think what we want to do is really walk this 


work group and this group carefully through 


this report. I think this report’s a very, 


very critical report on this whole question of 


completeness. And I think coupled with what 


we did on data reliability, I think does 


tackle what I think is the cornerstone of this 


review. 


MR. GRIFFON: Excuse me. If you’re on the 


line, could you mute your phone? We’re 


hearing some people talking so you might want 


to mute your phones, please. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

25 

DR. MAKHIJANI: Thanks, Joe. Basically the 


frame work of the review was provided by the 


Board’s criteria on the pedigree of the data 


and the methodology and internal consistency, 


and also the Board’s approval of our interim 


SEC review procedures which require us to 


review completeness of data. 


As Joe said, we reviewed two different 


kinds of samples from the data. One was a set 


of 32 developed over time which were random 


samples divided into two periods, the early 


period when there wasn’t universal monitoring 


which goes up to ’63, and then from ’64 when 


the ID badge was an integrated badge with the 


dosimeter and the identification in a single 


badge. 


Now we understood later on that 


subcontractor workers were not covered by the 


universal monitoring policy, but the jump in 


the percentage of monitored people in ’64, 


percentage of people wearing badges, that 


indicates that the percentage of people badged 


were in the 90 percents except for 1969 


through about 1990. So this analysis goes up 


to 1992. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

Nineteen ninety-two is a little bit 


anomalous here because that production stopped 


early in that year, so they went through the 


transition year to go into a decommissioning 


mode which was formally declared in 1993. So 


I’ll walk you through our findings. 


We divided this into external dose and 


internal dose findings, and we also just as a 


caveat on what kind of completeness review 


this is. This wasn’t a detailed completeness 


review where the whole record was examined for 


every gap. This was a broad screen review 


where we said the data had a gap, when there 


was no record for that year at all. If there 


was one zero reported, for instance, we did 


not count that as a gap. 


So it doesn’t mean that the record is 


complete or there’s a record for every badge 


cycle. So it’s a very broad screen that 


allowed us to go relatively efficiently to 


determine whether the gaps were large or not. 


And the use of the broad screen means, 


especially for external dose, that this is a 


minimal estimate of the completeness of the 


data. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

27 

So in the first table where we did the 


external dose analysis we found that for the 


early period we defined two kinds of data 


gaps. One was the proportion of workers who 


had a gap for one year or more. And then we 


defined a cumulative gap which is if you add 


up all the years for all 32 workers that were 


in each period and how many percent of those 


years were not monitored cumulatively. 


So just to run you through the numbers 


for external dose in the ’51 through ’63 


period. There were 14 workers in the sample 


and 29 percent of them had gaps of one year or 


more. And the cumulative gap was 21 percent, 


that is, of all, we multiplied the 14 workers 


by the 13 years. Twenty-one percent of those 


years were blanks. 


Then ’64 to ’92 there were 30 workers 


in the sample, and the percentage of workers 


with gaps of one year or more were 33 percent. 


Now there’s a statistical artifact in that by 


the way we defined the period because of the 


1992 transition year. Of the ten workers who 


had a gap of one year or more, four workers 


were in that, had a gap only for 1992. So if 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

28 

you exclude 1992, and we included it because 


that was the instruction of the working group 


and that’s how it was decided here, but if you 


exclude 1992, the gap goes down to about 20 


percent. 


And the cumulative gap for 30 workers 


multiplied by the number of years, ’64 to ’92, 


29 years, is ten percent. So gap is smaller 


for the second period which is what we would 


expect since there was this quasi-universal 


badging. 


Now in these numbers we did not 


include 1969 which is separate. Nineteen 


sixty-nine had partial or full gaps and so we 


have to, we just analyzed that separately, and 


it’s a separate action item on the working 


group. And so these numbers don’t reflect 


1969. And it’s also important to remember 


that these are gaps in the record, not zeros. 


So zero entries are counted as positive 


indications of recorded data. 


Then we looked at internal dose and 


the same data for the same set of workers, and 


for the ’51 to ’63 period number of workers 


with a gap of one year or more was about the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

29 

same, 29 percent. Now for internal dose we 


defined the gap when there was no measurement 


of any kind, either urinalysis or fecal 


samples or an in vivo count. So if there was 


one count of any of these types we counted as 


a year that had a measurement, and it was not 


a gap. So no internal dose measurement for 


the full year of any kind counts as a gap. So 


again, it’s a very broad screening. 


The cumulative gap for the early 


period was 12 percent of all the workers, 14 


workers, multiplied by 13 years. Twelve 


percent of those years were unmonitored 


cumulatively. 


One surprising finding was in the 


second period we found that 73 percent of the 


workers had a gap of one year or more, and the 


cumulative gap was 33 percent. So this, of 


course, raises the question of how the gaps 


are going to be filled. The reason to look at 


the highly exposed workers was to examine the 


question of whether the gaps can be filled and 


what questions it raises for coworker models. 


The highly exposed workers, 


quote/unquote, were defined by Rocky Flats 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

30 

review, retrospective review that was 


undertaken in the 1990s. They had a set of, I 


don’t remember how many workers they reviewed, 


but they had a set of workers that they 


reviewed for cumulative exposure where the 


internal and external was added up. And then 


they classified workers from one to four into 


exposure categories. 


And category four was the most exposed 


cumulative dose. Category three was the less 


below that, and category one had the least 


cumulative exposure. Now this doesn’t 


separate internal and external dose, and it 


doesn’t separate periods. So if somebody who 


had a high cumulative may not have been in the 


highest exposed category at some period. 


But it was an approximate guide to 


examining whether there were data available 


for filling in the gaps. It’s not definitive 


but indicative. What we found was, we again 


did separation of external and internal dose. 


We did not find any full year gaps in the 


internal dose for the highly exposed workers. 


We had ten cases from category four and ten 


cases from category three. And all of them 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

31 

had at least one measurement. 


Now it doesn’t say it’s complete in 


all respects but there was in this broad 


screening no gap in the internal dose 


measurements. Now we don’t include a screen 


as to whether every relevant radionuclide was 


monitored and so on. But every one of these 


20 workers had at least one measurement during 


each year. 


For external dose we did find some 


gaps -- there’s no table here so I’m trying to 


find the number. Excuse me. But the most 


significant gap we found was in group three 


workers, that is, in the workers just below 


the highest exposed workers in the ’51 to ’59 


period. So it turned out in the early period 


there were external dose gaps. 


And if you looked at a part of that 


early period, ’51 to ’59, the gaps were 


particularly large. Sixty-two percent of the 


cumulative employment years in group three 


workers were missing -- I shouldn’t say 


missing -- had blanks in their external dose 


records which indicate that maybe they were 


not badged in that period. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

32 

Now this was a period of partial 


badging of workers. In the earliest period 


there were the fewest workers badged and that 


proportion of badging went up as the ‘50s went 


on. And then in the ‘60s we did not find 


external dose gaps. 


We looked at the job descriptions of 


the workers, the job cards of the workers who 


had these external dose gaps and the group 


four workers in order to determine whether 


there was any pattern in their job assignments 


for why they may have been badged or not 


badged. 


Most of the full year gaps were 


associated with work in Production Plant B 


where depleted uranium and enriched uranium 


was processed. So as NIOSH has said that the 


uranium areas were the areas that were thought 


to have low exposures. So there was a 


systematic decision, at least the sampling 


indicates that there was a systematic decision 


that workers in plutonium areas would be 


badged and workers in uranium areas were. I 


don’t know if they were all done that, but the 


gaps are focused in those areas. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

33 

There were some gaps in Building 81, 


the QC Lab, something called the Pipe Shop. 


There were no full year gaps for people who 


worked in Production Plant C which were the 


plutonium workers. So that’s important to 


say. So there’s a clear division in how these 


gaps emerged. 


Now we looked at documents indicating 


exposure potential in the uranium areas and in 


a particular uranium area, the foundry 


operations, the foundry operations result --


let me go back. Uranium as a homogeneous 


material builds up its first decay products to 


equilibrium relatively rapidly, thorium-234 


and protactinium-234. And its external 


contact dose, shallow dose and deep dose, are 


relatively well-known to be maximum two millirad for hour for deep dose and about 240 for 


shallow dose. 


But if, in foundry operations, there’s 


a separation of the decay products, and the 


shallow beta dose rates can be pretty high, 


this is documented in an evaluation of the 


uranium areas. The depleted uranium castings 


where in the early years there were shallow 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

34 

dose rates as high as 2,000 to 3,000 millirads per hour, so in order of magnitude bigger 


than the homogeneous uranium metal contact 


dose that were documented. 


These were thought to be very high or 


extremely high and the problem persisted 


though apparently in lesser degree through 


1982 when the report was written. I think 


either this report or the 1969 report actually 


contains the extended quotation from the year 


1982 report documenting that. 


Now we have external dose data for the 


plutonium areas, and the question arises 


plutonium also itself does not have, 


plutonium-239, does not have a strong shallow 


dose component or deep dose component. There 


is americium-241 in the plutonium areas that 


provides the main shallow dose component, I 


mean deep dose component. 


And the question arises from this 


analysis is how do the plutonium -- well, 


there are two questions. How do the external 


doses in the plutonium areas, especially in 


the 1950s, correspond to the external doses in 


the uranium areas especially for shallow dose 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

35 

and would they be bounding? And that’s a 


question we could not answer from our 


analysis. 


And then secondly, from among the 


monitored workers in uranium, was there 


monitoring from the areas that had the higher 


exposure potential so you could possibly 


construct a coworker model? And that also we 


could not tell from this analysis. So that’s 


the main, other than 1969, which is separately 


covered, that’s the main issue which emerged 


from the completeness evaluation. 


There are two other issues, one I’ve 


already mentioned in regard to subcontractors. 


We did not find any evidence of any systematic 


avoidance, that subcontractors were sent into 


radiological areas and without badges, and 


then they were exposed in some nefarious way. 


We did not find any evidence that there was a 


systemic violation of the policy that would 


have resulted in unbadged subcontractor 


workers going into radiological areas. 


But we thought that some verification 


of enforcement would be desirable since there 


were unbadged subcontractor workers on site 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

36 

apparently throughout the period. And one 


possible verification that might settle the 


question which is at the present time sort of 


an expert statement which is somewhat in 


opposition to the statement that has been made 


by the petitioners is that the blanks in the 


records correspond to a systemic problem. For 


this particular problem one verification 


procedure might relate to the clean up of the 


fires after 1965 or 1969 to see if there were 


any subcontractor workers that might have been 


sent into radiological areas but had no badge 


records. 


The other issue that has arisen in the 


context of working groups discussions was 


that, on the completeness investigations was 


that of one particular individual who had, who 


was not a subcontractor worker, who was a 


prime contractor employee who had an eleven-


year exposure data gap from 1963 to 1973 


inclusive, and only one of those years was a 


year of when universal badging was not in 


place. 


Now this worker is thought not to have 


a high exposure potential, but ten of those 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

37 

years do relate to a universal badging period. 


And the question arises, especially when we 


discuss the 1969 gaps. Maybe you want to 


defer that question to 1969. What was the 


policy of badging for prime contractor 


workers? Or were badges issued and not read 


from 1964 onward in some way and what happened 


to those records. So that’s kind of an open 


question that also arose from this 


investigation. 


Sorry it took so long to present, but 


it was pretty complex. 


MR. GRIFFON: That’s okay. I just have one 


follow-up on the production workers. You 


said, I heard the external group three workers 


you found some gaps in the ‘50s. I think you 


said no gaps from ’64 through ’92 for the 


production workers? 


DR. MAKHIJANI: Yeah. From, I believe if I 


remember all the details correctly, from ’61 


onward. 


MR. GRIFFON: So it was mainly that ’52 


through ’59. 


DR. MAKHIJANI: Yes, ’51, yeah. 


MR. GRIFFON: And I know that at this point 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

38 

I guess we don’t need to cover ’69 yet, but I 


know at this point NIOSH has this report, and 


they’re reviewing it and going through it. I 


know that, and talking to Brant I know you’re 


not in a position to give a full response. I 


guess the only question I had was this, you 


know, just in terms of when we do get your 


response to this I still have this question of 


what are we measuring against? And I don’t 


know if you made any headway in resolving this 


question of, remember the ’69 memo where this 


policy apparently was put in place for not 


reading some of the badges from people that 


were wearing badges. But we never really 


understood if it was one year, if it 


continued, and I know you said you were going 


to look into that. I don’t know if you’ve got 


any update on that, but I think it would be 


nice for us to know. The better we understand 


the policies over time, the better we can 


understand the results here, you know, if 


they, if there’s anything to these results or 


if they are well explained by policies that 


were in place at the time. 


DR. ULSH: Well, you raise a good point 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

39 

there, Mark. We’ve got to keep in mind the 


overall purpose of this analysis. I think 


SC&A’s report gets us partway there in terms 


of how many years -- well, no, what time 


periods do you see where individual workers 


did not, there’s no monitoring results in 


their record. 


But the other part of the question is 


would you expect there to be records there. 


And I don’t think that we have that answer 


yet. That’s what we are doing. We have, 


we’ve had some discussions with SC&A on this. 


They’ve interviewed some of the site experts, 


and what we’ve suggested was -- and Arjun 


talked about this -- was that you have to look 


at the worker’s job exposure history card to 


determine whether or not you would expect them 


to be monitored. And that’s what we’re doing 


in our analysis now. 


I can tell you that we are seeing a 


lot of instances where, for the periods where 


there is no monitoring, that’s exactly what we 


would expect given the worker’s job duties at 


the time. I’m not in a position to tell you 


that that is the case in everyone because 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

40 

we’re not done yet. But we are seeing, again, 


just like in the first 12, that the workers’ 


job duties do explain at least some of these 


periods when there are no records for them. 


And, of course, as you mentioned, 


there are a couple of questions that this goes 


to. One is data integrity. I mean, do you 


have people who should have been monitored 


according to the badging policies in place at 


the time, and there’s no records, in which 


case you might conclude that those records are 


missing. The other question which is number 


three on your agenda is what effect might that 


have on the coworker data. And I’ll save that 


discussion for maybe that topic. 


Now in terms of the ’51 to ’59 period, 


so you’ve got to keep this separate from the 


’69 issue as Arjun mentioned, you know, that’s 


handled separately. But ’51 to ’59 I think 


it’s fair to say, Arjun, that we found, I 


think your report said that you found gaps in 


the Plant B workers, Building 81 more so than 


others, not exclusively, but there were more 


there. 


DR. MAKHIJANI: Yeah, I think you can say 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

41 

that there were not gaps in Plant B workers 


for full years, and then the gaps that were 


there were concentrated in the Plant B area. 


DR. ULSH: Right, and this was an issue that 


when you interviewed Roger that Roger brought 


up, that people in Plant B, Building 881, were 


not monitored in the ‘50s up until I believe 


it’s the fourth quarter of 1960. So we are 


aware of that. And the badging policy that 


was in place at the time, I believe, was that 


people who were expected to get less than ten 


percent of the tolerance weren’t required to 


be badged. And so that was why those people, 


that was the thinking about why those people 


wouldn’t have been badged. 


Now you have raised the concern in 


your report, but what about people in the 


foundry? I mean, they could get some pretty 


high doses, especially if they’re coming into 


contact with the castings or the sculls from 


the foundry. I would point out to you, 


however, that the foundry is not in Plant B. 


The foundry is in Plant A. 


DR. MAKHIJANI: Building 444. 


DR. ULSH: Four forty-four. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

42 

DR. MAKHIJANI: That’s why I said the gaps 


are, the way I characterized the gaps is that 


the gaps are not in Production Area C. They 


are in other areas. Right, we caught a lot of 


gaps in Plant B. 


DR. ULSH: Now Area C, I think, is the 


plutonium area, right? 


DR. MAKHIJANI: That’s right. 


DR. ULSH: So you’ve got, in the early years 


you’ve got A, B, C and D. Plant A is Building 


444. That’s where the foundry was. That’s 


where you might see some of these high doses, 


like you said in your report. Plant B where 


you’re seeing a lot more of the gaps is 


Building 881. It’s not the foundry. 


MR. GRIFFON: Is it your understanding, or 


Roger’s understanding that those foundry 


workers should have been –- you know, based on 


the ten percent? 


DR. ULSH: We’re looking at that right now. 


I think, the indications that we have so far 


are that their doses were low, but, Mark, that 


may not be my final word on this. We’re 


looking at it right now. 


MR. PRESLEY: Brant, it’s Bob Presley, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

43 

question. Those early years in that building. 


Those production years are those years that 


Rocky was going in there and fabbing the 


buildings and fabbing the process equipment 


and things like that. 


DR. ULSH: Bob, I can tell you Building 881 


was built in 1952, I believe, maybe ’53, 


something like that. I can’t tell you when it 


actually came on line and became hot. 


MR. PRESLEY: Then that may be one reason 


you’ve got gaps in those things. 


DR. ULSH: Could be, I’m not in a position 


to say that that’s it. 


MR. PRESLEY: But I mean that’s a 


possibility that those people were not 


production workers, but they were construction 


workers, and that building wasn’t hot, thus, 


they weren’t monitored. And that was a 


practice that we did from day one throughout 


the complex. 


DR. ULSH: That is true, Bob, and that’s why 


we’re looking at the job exposure histories to 


come at it from that question. So I mean, to 


get at would you expect there to be monitoring 


here and we don’t have any. That would say to 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

44 

you that there might be a data integrity issue 


here. There should be monitoring results. 


People should have been monitored, and they’re 


not. We’re not in a position to offer an 


opinion on that just yet for all of the 


workers and say that some of them --


MR. GRIFFON: Again, to me it’s, I think 


it’s much more useful to see as best you can, 


and I know you found some of this pieces of 


this, but the policies of the time, you know, 


the written policies, indication that here’s 


how we made this decision. Here’s who was 


badged. 


I mean, I think you need to look at 


both, but you can look at these jobs, and you 


probably have a lot that are clear-cut one 


way; a lot that are clear-cut the other way. 


And then you’ve got some of these murky ones. 


But if you have a policy then we have a 


brighter line to test, so as best we can find 


some of those things, that’d be helpful. 


DR. ULSH: I agree with you, Mark, and after 


our last working -- well, after one of our 


previous working group meetings when we 


discussed the first 12, and there was some 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

45 

confusion about what the badging policy was, 


Jim Langsted put together a write-up on the 


badging policies. The date on the copy I have 


here is December 6th . I don’t know exactly 


what date that was sent out, but that has been 


sent out. 


MR. GRIFFON: I’m sure we got that, yeah. 


DR. ULSH: So you’re right, that’s the other 


piece of the puzzle in answering that 


question. But I did want to point out, I 


mean, going to the second question, what 


effect might it have on coworker models. You 


would obviously be concerned about the areas, 


the operations in the uranium areas where 


there was a potential for high exposure and 


the foundry may be one of those places. 


But again, the foundry is in Plant A, 


not Plant B. Plant B is where you’re seeing a 


lot of the gaps. So I just wanted to point 


that out. We still have to go through the 


individual cases. 


Arjun, I think there at the end --


okay, well, one other thing I wanted to talk 


about was the group three workers you 


mentioned, I think, that there were some gaps 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

46 

in the group three workers in the ‘50s. And 


again, the group three and four workers were 


the ones that were identified in the Medical 


Recall Program as having had the highest 


exposures onsite as Arjun mentioned. 


But the other point that you have to 


consider is when did they become, when did 


they achieve that status? When did they 


become highly exposed individuals? So you 


shouldn’t assume just taking one of these 


group three or group four people if you see a 


year when they were not monitored in 1953 and 


say, gosh, this is a highly exposed worker. 


Why wasn’t this guy monitored? He might not 


have had a big uptake, a big intake incident 


or a big external exposure incident until much 


later. I mean, that’s a possibility. 


MR. GRIFFON: And a lot of them moved from 


uranium areas to the plutonium area. 


DR. ULSH: Yes, that is true. So again, you 


have to look at the job exposure history even 


for those people as well, and we are doing 


that. 


Now in terms of the ’69 fire I believe 


that you brought up a point about were subs 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

47 

possibly going into the building. 


DR. MAKHIJANI: No, no, just to clarify what 


I said. In regard to subcontractors, we 


didn’t find evidence of systemic violation. 


What we suggest, and so that would appear to 


corroborate to some extent the site expert 


statement that has been made, but there’s no 


documentation of enforcement of that policy 


because obviously it leaves some room for 


problems. That you had subcontractor workers; 


you had a problem onsite; you had a fire; you 


had an incident, and you had a need for 


workers and people were sent in without 


badges. Because there are statements in the 


petition about those kinds of problems, not 


directly about subcontractors. And so the 


suggestion was that some kind of verification 


of enforcement be made. But if subcontractor 


workers can be identified who were sent in, 


for instance, to clean up after the fire that 


they were actually badged. We haven’t made 


any statement about whether they were or not 


or whether there are gaps in that area or not. 


MR. GRIFFON: I was just going to ask, and I 


know you sent out that paper Jim Langsted 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

48 

wrote it on the policies -- maybe refresh my 


memory. By the time I found it on my hard 


drive it’ll probably be one o’clock. So does 


it speak to this question of when did this 


policy of reading, you know, everybody had the 


security badge with the TLD or film in it, and 


they didn’t read them all and in ’69 that 


started. 


DR. ULSH: You’re talking in ’69. Let me 


give you --


MR. GRIFFON: Well, it started in ’69. We 


saw that in the memo, right? But we’re not 


clear when it, how long that policy was --


DR. ULSH: That is correct, Mark. 


MR. GRIFFON: Well, how long was that policy 


in effect or do you know? Okay, that’s the 


question. 


DR. ULSH: I know. This is the question 


that we’ve been hoping to come up with an 


answer for for awhile. 


The ’69, the policy not to read badges 


of workers who were on quarterly badge 


exchange cycles in non-plutonium areas, the 


first indication in the documentation that 


we’ve seen of that was in a monthly progress 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

49 

report, I believe, in April of ’69. And 


that’s in actually SC&A’s report on that. It 


pulls out the quote. That was the first 


indication of when it started. We still have 


not found any indication of when that policy 


might have been rescinded. 


Now, one thing that we are checking 


on, you’ve also got to remember that the 


justification for this that was given in a 


letter -- I don’t want to say the name, but --


was that the reason they wanted to do that is 


because these people -- let’s define cohort 


people -- had low exposure potentials, right? 


And it was a lot of effort involved in reading 


badges, using densitometers to read the film 


badges, and it may not be the best use of your 


resources, something like, it’s not a direct 


quote. 


In late ’70 or maybe it was ’71, the 


site switched to TLDs, and so that same 


argument may not hold in terms of being a lot 


of effort that could be better spent 


elsewhere. Now, we are trying to look and see 


whether those people that would have been 


covered by this policy, the non-plutonium 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

50 

areas on quarterly exchange cycles, whether 


their TLDs were read. We’re checking on that. 


I don’t have an answer for you there, but 


that’s a possibility. I don’t know. 


MR. GRIFFON: And then the other question, 


and I don’t know if, I’ve got to admit I 


forget, I did read it, believe it or not, but 


I forget what it said. This question I 


remember in one of the meetings it came up 


with not only was there this new or this memo 


that we found about this policy, but there was 


also another explanation that I thought was 


given which was that some personnel or some 


subcontractor -- this gets into the 


subcontractor question -- some subcontractors 


did not require any monitoring? Was that 


brought up as a policy after ’64 or any time 


period? I’m trying to remember. I thought 


that was brought up as a possible explanation. 


MS. MUNN: We have this one quote that was 


in a (inaudible), subcontractor (inaudible) 


not have been issued a dosimeter. 


MR. GRIFFON: What are you reading from? 


Which document is this? 


MS. MUNN: This is the Rocky Flats Badging 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

51 

(inaudible). 


MR. GRIFFON: So it’s SC&A’s report? 


MS. MUNN: No, I think it’s (inaudible). 


MR. GRIFFON: Can you read that, Wanda? 


MS. MUNN: Yeah. On the badging report that 


was sent out in December that the statement 


was, however, subcontractor personnel with low 


exposure potential may not have been issued a 


dosimeter, and then it quotes paragraph 


6.15.1, conditions where general Health 


physics surveillance was not required: (a) in 


areas where penetrating radiation levels are 


not likely to exceed an average of 0.2 


millirem per hour, comma, outside contractor 


personnel may be utilized. Film badges will 


not be provided under these conditions unless 


on advice of Health physics, badging is 


desired for assessing a possible criticality 


exposure, end of quote. Health physics guide 


for Rocky Flats division compiled by EA 


(unintelligible), first issued July 1961, 


reviewed January 1967, re-issued January 1970. 


Section renumbered 5.1.7. 


MR. GRIFFON: Well, I guess that’s the 


question. If some of these people that we 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

52 

reviewed for completeness fall into that 


subcontractor category, then they may not have 


been required according to this policy to --


DR. ULSH: That’s what it appears to 


indicate. 


MR. GRIFFON: And we don’t necessarily know, 


or Arjun, you don’t know whether these 


individuals were subcontractors or primary 


contractors based on the records you were 


looking at, do you? 


DR. MAKHIJANI: No, we didn’t go to that 


depth. 


MR. GRIFFON: So that’s where we’re headed. 


I knew that statement came up before. 


DR. MAKHIJANI: Well, actually in the job 


cards that I reviewed, I didn’t see, I mean, 


they were pretty much production workers in 


category three and category four so far as I 


remember, and there may have been exceptions. 


MR. GRIFFON: The broader, the other --


DR. MAKHIJANI: The other sample? No, we 


didn’t look at that. 


MR. GRIFFON: So that’s what we’re engaged 


in right now. 


DR. ULSH: Okay, Mark, so that’s where we 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

53 

are with the question of when did this non-


badge policy end. We are pursuing that. I 


don’t have an answer. I know it’s still an 


issue of concern. 


Now in terms, Arjun, I understand your 


concern about the subs, that it would be nice 


to have some verification that this policy was 


actually enforced. And I can’t speak to the 


general issue, but the specific example that 


you used, the 1969 fire, I can tell you that 


we spent a lot of time on that ’69 fire and 


some of the interviews I believe that Mel 


conducted and maybe even some documentation. 


I can’t remember exactly, but right 


after the fire, the immediate aftermath of the 


fire, only professional staff were sent in. 


There were very little number of them. I 


don’t want to give a number because I don’t 


remember exactly what it was. And they were 


badged. It wasn’t subs that went in 


immediately after the fire to recover the 


plutonium because there was a concern about 


criticality. So that’s the immediate 


aftermath. 


Now, after the plutonium that was 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

54 

involved in the fire was removed from the 


building then there were a lot of cleanup 


activities involved. Of course, this is 


another thing, and we see a couple of times 


here in SC&A’s reports, in the aftermath of 


the fire, once the plutonium has been removed 


from the building, and there’s no production 


operations going on, of course, the external 


exposure potential goes down. You can’t 


assume that the same exposure potential exists 


as there was in full production. In fact, 


it’s exactly the opposite. 


DR. MAKHIJANI: There shouldn’t be a 


misunderstanding about what the suggestion is. 


The suggestion is in fact that subcontractors 


were at high exposure potential or not when 


they went into radiological areas. The 


suggestion was simply a response to the 


statement that was made, I believe in 


November, that subcontractor workers were 


badged when they were sent into radiological 


areas which would fit. 


If they were sent for cleanup, that 


would in my definition at least be a 


radiological area. And they may not have been 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

55 

at risk of external exposure potential, but 


they may have been at risk of internal 


exposure potential. If they were not badged 


and sent into radiological areas, then there 


would be a kind of systemic, if that were a 


problem, then there would be some 


corroboration of what the petitioners have 


been saying. 


And so the concern that is being 


raised is, yes, there’s been a statement by 


NIOSH, and yes, we did not find any evidence 


that that statement is incorrect. But it 


stands so far undocumented and uncorroborated, 


and it would be useful to have a corroboration 


not of high or low exposure potential, but 


whether there were subcontractors who were 


sent into cleanup areas whose records indicate 


that they were not issued badges. 


That I think is an important item 


because it corresponds directly to the 


concerns that the petitioners have raised. 


And I think we have tried to address those 


systematically and this one should be also. 


Some verification is desirable. That’s the 


statement that we’ve made. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

56 

DR. ULSH: Okay, Mark, I think that’s all 


I’ve got on that at the moment. 


DR. MAKHIJANI: Just a comment about the 


badging policies, I mean, we didn’t raise any, 


I mean, the part of the reason to look at the 


job cards was to verify the statements that 


NIOSH has made. And I think broadly we did 


verify it. We did only a preliminary look at 


these job cards. It was rather rapid, and it 


did result in a confirmation that the nonbadging and the gaps were in the non-plutonium 


area. So actually, we did confirm what has 


been said many times by NIOSH. And so I think 


that much has been validated. 


The question about dose reconstruction 


that it raises is not confined to what the 


badging policy was and whether it was regarded 


as reasonable or done in good faith at the 


time. And we haven’t said that it wasn’t, and 


I think in fact what we found that it was. It 


was done in good faith. People who were 


thought to be at not high exposure potential 


were not badged. 


In retrospect though NIOSH can’t use 


the policies that were in effect then to do 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

57 

dose reconstruction. They have to do dose 


reconstruction according to today’s standards, 


and that’s the question that I think is raised 


by the gaps in ’51 to ’59 is are the gaps in 


the areas that had high exposure potential 


where there were systemic lack of badging and 


how are those gaps to be filled by today’s 


dose reconstruction standards. 


And we’re not saying that in this 


particular case some policy at the time was 


violated. We didn’t find that. On the 


contrary we found that NIOSH statements were 


generally correct. 


MR. GRIFFON: And I think we can’t go much 


further with that until we see your findings ­

-


DR. MAKHIJANI: Exactly. 


MR. GRIFFON: -- and you do your final 


analysis on that yet. 


MR. ELLIOTT: Let me just make sure I 


understand what I hear Arjun saying here that 


in essence, and this goes back to the 


verification comment he made, suggestion he 


made to us. In essence you validated what we 


have made as our stated position, and you’re 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

58 

suggesting that there’s a way here to further 


verify and confirm that validation. 


DR. MAKHIJANI: No, no, you’re mixing up two 


separate issues. One issue was sort of a 


subsidiary issue for a small proportion of 


workers who were subcontractors, whether they 


were sent into radiological areas without 


badges. And that was just a verification. We 


found no evidence of that. So that was a 


verification suggestion for that. 


MR. ELLIOTT: That’s exactly what I was 


referring to. 


DR. MAKHIJANI: Yeah, but that’s completely 


separate from the data gaps for the 1950s --


MR. ELLIOTT: I understand. 


DR. MAKHIJANI: -- which were a result of 


policy of who was badged and who was not 


badged, and we didn’t find any evidence that, 


you know, there was some systematic effort in 


the ‘50s to hide doses of highly exposed 


people so therefore, they were not badged. We 


found some confirmation that people in 


plutonium areas were badged, although as I say 


it’s a broad screen what the gap is. And that 


people in non-plutonium areas were not badged, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

59 

not all of them, but the non-badging was 


focused in the non-plutonium areas. 


MR. ELLIOTT: I think I’m saying the same 

thing. 

MR. GRIFFON: Okay, okay. 

DR. MAKHIJANI: But that latter problem is a 


coworker model problem, not a verification 


problem. 


MR. GRIFFON: I guess with respect to the 


first question, the subcontractor question, I 


think is there an action there is my question. 


Is there an action on NIOSH’s behalf? We’ve 


got a statement by, concerns various other 


petitioners, and you’re saying we’ve had a 


response that it was the policy at the time to 


badge them if they were in the RAD areas, but 


we have nothing to really support that, and 


you know, I think the action would be give us 


some data that supports that. I’m not sure 


what exactly that would be, but is that sort 


of what you’re raising here? 


MR. ELLIOTT: What I’m hearing is their 


understanding is no different than ours. 


They’re suggesting a way to verify and confirm 


that we’re both on the same --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

60 

MR. GRIFFON: Right, we haven’t seen --


MR. ELLIOTT: -- it goes to helping out the 


petitioners understand what we’ve all done 


here, and how we’re reacting to their --


MR. GRIFFON: Arjun’s saying we haven’t 


found any problems there, but we haven’t 


either seen the verification of that either, 


right? 


DR. ULSH: Well, what I’m wondering, Arjun, 


is if -- and I really don’t know this -- in 


the ’52 that we’re looking at are there subs 


included in there? 


MR. GRIFFON: That’s what I asked. 


DR. MAKHIJANI: I did not look at the job 


cards for 32 random sample workers so I don’t 


know. I do not believe that from my 


preliminary review there were subs in the 


category three and category four workers. 


MR. ELLIOTT: I’m simply saying what I’m 


taking away from this is that you see things 


the same as we stated, and you’re providing us 


a constructive suggestion on how to verify 


what we both have seen. 


DR. MAKHIJANI: Yes, in terms of the reasons 


for the gaps and in terms of the overall 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

61 

completeness picture apart from how you’re 


going to do dose reconstruction, yes, we have 


no differences, and we didn’t identify that 


any statement that NIOSH made was incorrect. 


We’re just suggesting one, there is one 


outstanding question that relates more to the 


’69 but goes not only forward from ’69 but 


back from’69 is what happened in the case of 


the types of individuals that have, that were 


primary contractor employees who have blanks 


before ’69. And that’s a separate --


MR. GRIFFON: We’ll hold that. 


DR. MAKHIJANI: Yeah, we’ll just hold that. 


That’s the one exception. 


MR. GRIFFON: So that’s a question that is a 


potential action item. It would help, I think 


you’re right, Larry, it would help support 


that position and verify that to a further 


extent. 


MR. FITZGERALD: In the context of this step 


I think more to validate the earlier limited 


sampling that, in fact, these gaps were there, 


were real and a larger sample helped answer 


that question, but I think that’s as far as it 


went, just to, in fact, substantiate that 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

62 

these gaps are, in fact, real. Now as far as 


the reasoning and interpretation, I think all 


that needs to follow. 


MR. GRIFFON: And it may be if you look 


through these 32 job histories, and you find 


some subcontractors, and it shows that they 


were, in fact, monitored, that might answer 


the question. That might give us some 


evidence to support that position. 


Now you may look at those 32 and find 


that none of them were subs, you know? But I 


don’t know if you can easily identify within 


the claimant files, it may not be so easy to 


pull out who was a sub without looking -- is 


that something easy within the database that 


you can look up individuals and --


DR. ULSH: It seems to me that it would be 


fairly easy, Mark, to look at the job exposure 


history cards if they exist for subs. 


DR. NETON: I believe they do. 


DR. ULSH: Something to check. I mean, this 


is a way to go in and pick out a case by hand 


and say there’s a card here. Is he a sub? 


Well, nothing here, next guy. But in terms of 


like doing a sort on NOCTS or something to 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

63 

pull out subs, I don’t think we have a way to 


easily do that. 


MR. ELLIOTT: Unless they reported their 


employment as with a specific contractor who 


was at the site. 


DR. NETON: I think we need to check with 


Mel. He’s done a lot of work on this with 


252. Rocky Flats was one of the example sites 


that we used to determine whether 


subcontractors and Rocky Flats main workers 


had differences in external dose profiles. In 


fact, that analysis found no difference, and 


they went to a large extent to pull out as 


many records as possible to identify 


subcontractors. I think we ought to look at 


that. 


There were building trades workers, 


subcontractors, but I think we ought to look 


at that because a lot of work has been done in 


that area. 

MR. ELLIOTT: That’s true. That didn’t 

occur to me. 

MR. GRIFFON: That may be useful. I guess 

that might be an action item, but I would also 


say -- I don’t know how to say this. I mean I 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

64 

think we need to control the scope of that, 


and I think you need to control the scope. It 


would be good to have some evidence toward 


that, but I don’t think that I would expect 


you to pull hundreds, you know, if you find a 


few subcontractor files or randomly find four 


or five or whatever that seem to support this 


position, that would be pretty good evidence 


toward the, you know. 


DR. ULSH: Going forward, Mark, I just want 


to make sure that I know what the work group 


is expecting. Are we going to finish up our 


analysis of the 52 and let you know whether or 


not subs are included in there and then get a 


feeling from the Board whether or not that 


will suffice or is there an action item at 


this time that you want us to go pick out some 


subs and --


MR. GRIFFON: Well, I would say pending your 


analysis of the 32 if there’s no subs in 


there, I think you should go and find some 


subs. And I’ll let you define some, but I 


would think keep it a small sample. 


MR. ELLIOTT: And look at this TIB-52. 


MR. GRIFFON: Yeah, and maybe the TIB-52 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

65 

already has done some of that. 


MR. ELLIOTT: I would ask that you put that 


second, and then if that doesn’t produce 


enough, then you go find some subs to look at. 


MR. GRIFFON: If the work is done already 


obviously don’t spend additional resources, 


right. But I’m not, well, I don’t know. I 


don’t know how the subcontractors work, but if 


buildings trades are in TIB-52, and these were 


subcontract maintenance people, it may not, I 


don’t know if it’s apples and apples but you 


can find that out. 


DR. NETON: But we need to at least look at 


that so we don’t duplicate our --


MR. GRIFFON: Certainly as efficiently as 


you can. If you’ve got the work done already, 


use that, yeah. 


MS. MUNN: And the methods Mel used might be 


useful, too. 


MR. GRIFFON: Yeah, I guess that’s what I 


would say. 


And I think we have the ’69 data gap 


coming up, but I’ve got a request for a short 


break, maybe ten minute break. We’ve got some 


microphone issues, and we’ll take a comfort 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

66 

break. So ten minutes, I think we’re going to 


keep the line open if that’s okay with 


everyone. And we’ll be off the record now. 


(Whereupon, a break was taken at 11:14 a.m. 


and the meeting resumed at 11:29 a.m.) 


MR. GRIFFON: I think we’re ready to 


reconvene here, and I think, unless there’s 


anything else on that first item, I think item 


two --


DR. MAURO (by Telephone): Excuse me, Mark, 


this is John Mauro. Before we leave the 


subject I just was, Arjun had mentioned during 


his presentation it sounds like one of the 


issues is that a group of workers where we’re 


finding gaps, and I think everyone agrees that 


there are gaps. Are these workers either in 


the uranium areas or foundry areas where they 


were not monitored for externals. 


But I also heard Arjun say that one of 


the concerns there is that under certain 


conditions the contact dose is on the order of 


two-to-three rem per hour when you have this 


thorium and protactinium sort of surface, and 


also that there might be, in other words not 


the standard 240 millirem per hour for contact 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

67 

and two millirem per hour penetrating. I 


think that two millirem per hour is at one 


foot. 


I’d like to hear a little bit about 


has NIOSH been looking at that particular dose 


reconstruction challenge. In other words how 


to deal with workers who may have a gap, not 


monitored, and may have been involved in 


handling or working with foundry operations. 


Is that something that they feel they’ve got a 


good handle on and it’s tractable? Or do they 


think there are certain aspects to that aspect 


of dose reconstruction that they’re still 


struggling with? 


MR. GRIFFON: I think what we heard is it’s 


a little premature for that because they’re 


still looking at the Plant B versus foundry 


question, but I don’t know. Brant might have 


something to add onto that. I think it’s a 


discussion better saved for the next meeting. 


If we find that some of the foundry workers 


were not monitored then that might be a more 


relevant topic of discussion. I don’t know. 


Brant, do you have anything? 


DR. ULSH: That’s exactly right, Mark. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

68 

That’s why I made that distinction, 


John, between Plant B and the foundry. The 


gaps, as I understand it, that Arjun saw were 


more for Plant B workers. I don’t want to say 


only for Plant B workers, but more for Plant 


B. But that would not include the foundry 


workers because they were in Plant A. 


Now the remaining question is were 


those foundry workers in Plant A monitored or 


not. And that’s what we’re going to try to 


establish as we go through the 52 cases and 


see whether or not we have some input on that. 


DR. MAURO (by Telephone): Okay, thank you. 


DR. MAKHIJANI: Just from my recollection of 


the review of the job cards I don’t remember a 


lot of workers in that sample from Plant A. 


So I don’t know whether we might have a small 


numbers problem in for the 1950s because we 


weren’t initially screening for that, to 


sample that particular population. And so we 


might have a small numbers problem there that 


you’ll need to do a more definitive look at 


that. 


DR. ULSH: Right, that’s the first step. 


The first step as you said, Mark, is to look 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

69 

at these 52. But if we don’t find the answers 


there, we agree, Arjun, that it would 


certainly be an issue if there are people who 


were not monitored and had high exposure 


potential. We just have to look at that and 


see whether or not those foundry workers were, 


in fact, monitored. 


DR. NETON: I think this is primarily a skin 


dose issue that we’re talking about here which 


is a beta-type exposure. So you need to be 


looking at things like extremity exposures and 


shallow dose to the skin primarily because 


these are not two R per hour deep penetrating 


doses for the most part. 


DR. MAURO (by Telephone): Jim, John again. 


One of the calculations we have not done is to 


see, we are aware of the contact dose issue. 


We weren’t quite sure whether or not the two 


MR per hour at one foot would also be affected 


by the fact that you have more of the 


protactinium close to the surface and whether 


or not that would change anything. I don’t 


have a sense of that. 


DR. NETON: You’re going to have a little 


more (unintelligible) coming off of there, but 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

70 

I think it’s primarily a beta dose issue is 


what these contact doses are. But if that’s 


the case, then it really becomes a skin dose 


issue which is then not an SEC cancer although 


it doesn’t mean it couldn’t be --


MR. GRIFFON: Although we’re looking at it 


in the construct of completeness, so if these 


people weren’t monitored. And if they’re 


monitored for skin, they would also be 


monitored for deep. You should see their 


records, right? So that’s really the issue 


there, but I understand your point. 


DR. MAKHIJANI: You also brought some deep 


gamma issues in relation to the daughter 


products. 


MR. GRIFFON: Yeah. 


DR. MAKHIJANI: Potential. 


DR. NETON: But it’s just not in the order 


of two rem. 


MR. GRIFFON: No, no, certainly not. 


DR. NETON: Most of that is beta. 


MR. GRIFFON: Yeah, yeah, we agree on that. 


All right, I think this discussion is better 


served for when we have NIOSH’s response and 


have more data in front of us. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

71 

1969 DATA GAP
 

Let’s move on. The second item, the 


’69 data gap, and I think this overlaps quite 


a bit with the first topic. But obviously, 


we’ve been looking at the specific problem for 


awhile of questions about blanks in data in 


the ’69 time period. So I’ll throw that to 


Joe or Arjun. I’m not sure who’s --


MR. FITZGERALD: Yeah, I want to take a 


second just to sort of summarize how we got 


here because it does have a kind of 


convoluted, somewhat long history. I think 


some history would be a little dim at this 


point. 


But during the course -- and I’m 


paraphrasing from our review -- during the 


course of SC&A’s review a number of former 


workers from Rocky Flats were interviewed, and 


a number of them expressed concerns about the 


’69 fire. And Kathy Robertson-DeMers, in 


fact, spent a lot of time looking at the HIS20 database and some of the records and found 


blanks and certainly zeros reported for a 


number of these workers. 


And from that we compared notes with 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

72 

work that Ron Buchanan was doing looking at 


external dosimetry pretty much records in 


terms of dose distribution, and in parallel, I 


think he established for ’69 and ’70 that 


there were a higher preponderance of zeros 


recorded for that time period. 


And that was something that we shared 


with NIOSH, and I think it was sometime in the 


summer. And NIOSH went forward to basically 


look at the historic record to see if there’s 


any explanation for why we would see these 


zeros, in some places blanks, particularly in 


’69-’70 timeframe. 


NIOSH came back, I think it was 


sometime in the fall with at least two or 


three explanations, hypotheses, as to what may 


have occurred. And one was certainly that it 


was an administrative decision. I think we 


touched on that already that there was, in 


fact, a policy that was put in place. And 


then there was maybe a computer programming 


error, but I think clearly we’ve established 


that the policy, in fact, was the reason that, 


a large reason why we were seeing these zeros. 


And the evaluation that we, in fact, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

73 

performed was to go back and look at the 


claimant files for the individuals that were, 


in fact, identified for this period. And 


there were 136 claimants that NIOSH identified 


originally of which 35 had no external 


dosimetry data at all for 1969. That’s kind 


of a starting point for the review that Arjun 


and Kathy Robertson-DeMers did because I’m 


going to just let you catch up on the review. 


And I don’t think this has actually 


cleared Privacy Act review yet, so this is 


something that with that one step we can 


certainly, NIOSH provided. 


DR. MAKHIJANI: Yeah, we’ve examined the 


data relating to claimants, but I just want to 


put a caveat about that in relation to all 


workers. We had this discussion in relation 


to the Nevada Test Site that really the goal 


in an SEC is to examine the data for the class 


of workers who are covered by the petition, 


not the class of claimants. 


And there’s no systematic procedure as 


yet for relating claimants to the whole group 


of workers statistically. That said, we all 


agree I think that it’s very important to look 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

74 

at the data that we have accessible which is 


the data of the claimants. And that is fairly 


plentiful so it’s important to look at it. 


As Joe said we looked at the HIS-20 


database and found a number of zeros in 1969­

1970 went up and that was the cause of the 


whole investigation. At first it might have 


been hypothesized that it may be associated 


with the fire, but NIOSH said that it was not 


associated with the fire. There may be other 


explanations, and I think we’re in broad 


agreement that it was not primarily associated 


with the fire. 


We looked at the various explanations. 


Just to make it short we have some questions 


about whether the computer error is relevant 


to this particular issue or not. But there 


was an error in the computer records, and 


these gaps might be related to that. We do 


agree that prior to the fire there was a 


policy put in place not to read badges of 


workers, or certain badges of workers in non-


plutonium areas and that that the gaps 


appeared to be, at least were largely related 


to this policy. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

75 

Now when this policy was, now we know 


the policy started before the fire in 1969 and 


then went on after that for some time, 


probably into 1970. We don’t know how far 


beyond 1970 it might extend. And as I said 


earlier in the completeness presentation, 


there’s also some indication that it may 


precede 1969. 


Now whether primary contractor workers 


were not being issued badges in the ’64-’69 


period and so there are gaps or they were not, 


they were issued badges that were not read is 


not so clear. NIOSH had said the former, but 


we don’t have any documentation about that or 


any policy statement that’s comparable to this 


1969 report where a policy was adopted. 


There was a rather more unfortunate 


aspect to the 1969 policy. So we did 


corroborate that the non-reading, which was 


about 1,000 badges in every cycle were not 


being read, so quite a large number of badges. 


We found that to issue badges and not read 


them is not a sound policy, but the problem 


was made much worse by discarding, the policy 


of discarding the badges after a few weeks. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

76 

So there’s now no way to go back and verify 


whose badges were actually not read because 


apparently the badges were discarded. 


We looked at the various external dose 


databases to see who this affected and how it 


affected them and what was actually entered 


into the record. There were four, the four 


different databases where external dose data 


are entered that are available in the claimant 


files, there’s the occupational dose report, 


which is the handwritten summary dosimetry in 


the Health Physics file. 


There’s a dosimetry history by 


individual which is a computer printout 


generated prior to the HIS-20 database 


creation. There’s the Health Physics External 


Radiation Exposure Report, which is a 


quarterly summary report. And there’s the 


HIS-20 computerized database which NIOSH is 


using for its coworker model. 


And so we looked at all four of these 


to examine the evolution of how these zeros 


got entered into the HIS-20 database. We 


looked at 19 individual workers who are all in 


the HIS-20 database. And there was one case 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

77 

of a worker who’s not in the HIS-20 database 


just missing as part of the group of workers 


that are not in that database whose case was 


also important because there was a gap in 1969 


in the data processing, the original log 


books. 


We looked at NIOSH’s explanation that 


where in the original badge processing logs 


there’s a zero across the place where the dose 


is entered with arrows going down that --


MR. GRIFFON: Excuse me, everyone on the 


phone. We’ve got some interference coming 


through from someone’s phone. I don’t know if 


someone’s on a cell phone or changed through 


speaker. Whatever you’re doing now, do what 


you were doing before. 


DR. MAKHIJANI: Where was I? Yes, the zeros 


that were in the film processing logs that 


went down with an arrow at the dose, but there 


was no densitometer reading, seemed to 


indicate the times, at least in the year in 


1970 when the badges were not read. And in 


those records the Health Physics External 


Radiation Exposure Report generally shows gaps 


or there’s nothing. But the dosimetry history 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

78 

by individual in the HIS-20 database actually 


replace the blanks by zeros. 


So as a result now the HIS-20 database 


has got two kinds of zeros that are mixed up. 


There are zeros that were entered because a 


result, a badge was read and was less than the 


detectable limit, and there are zeros because 


a badge was not read that was actually issued. 


And because the badge has been thrown away, 


this raises some pretty serious questions 


about data integrity. 


We didn’t find that there was an 


intent to fabricate data, to actually write 


zeros when there were high readings or 


something like, but to write zeros where there 


was no actual reading of a badge is a problem 


in data integrity. And this database, 


therefore, where there are zeros is 


fundamentally flawed in that respect. 


So unlike the earlier discussions we 


had about gaps, there is this extra problem in 


the HIS-20 database where --


MR. GRIFFON: Arjun, you might have said it 


already, but how many individuals did you find 


this flaw? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

79 

DR. MAKHIJANI: Well, we looked at 19 


individuals who had complete blanks, we looked 


at 19 individuals whose badges we determined 


could not be read, and I think we had that 


same understanding of whose badges were not 


being read, as NIOSH. 


MR. GRIFFON: Excuse me, we’re still getting 


bad interference from someone’s phone, so I 


don’t know if people, if you’ve done something 


differently maybe hang up and dial in again or 


try a different phone. We’d appreciate it, 


very loud static coming through. And it’s 


stopped now. 


DR. MAKHIJANI: So maybe I should have said 


something about how we pick the 19 claimants 


to look at. Nineteen sixty-nine is peculiar 


in that we actually looked at workers with 


partially complete, partially incomplete and 


partially complete gaps. So there are workers 


who had gaps for part of 1969. There are 


workers who had gaps, that is, badges not read 


for all of the year. 


So we thought to focus on those 


workers who had gaps for the whole year 


because that way we could determine whether 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

80 

the zeros that are in the HIS-20 database 


actually correspond to gaps or not because 


otherwise it’d be rather more difficult. And 


so we focused on 19 individuals who, among the 


1969 workers who did not have any external 


dose records in their original badge 


processing files, whose badges were not read, 


and examined what was there in the other 


databases where their doses were recorded. 


And as I said the result was that in 


the dosimetry history by individual computer 


printout, out of these 19, there were zeros 


for ten individuals instead of the blanks or 


gaps, and there was no dosimetry history by 


individual file for nine individuals. And for 


all 19 cases the gaps or blanks have been 


replaced by zeros in the HIS-20 database. 


So that was the result of that 


analysis. And you have the case-by-case 


analysis in the full report which is covered 


by the Privacy Act, with you. So there could 


be a number of, so the conclusion is that 


unread badges were being entered as zeros in 


the HIS-20 database. And to some extent also 


in the dosimetry history by individual 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

81 

computer printouts. So the problem seems to 


have originated somewhat prior to the HIS-20 


database but was carried over and aggravated 


by the HIS-20 database compilation. 


There are a lot of reasons for concern 


about this conclusion. We looked at the same 


workers’ records for 1968 and 1971 to see 


perhaps whether the zeros might correspond to 


a situation where they had no exposures in the 


earlier years but their badges were actually 


read. And we found that there was an increase 


in the number of zeros from ’68 to ’69, that 


there were workers who had non-zero doses 


recorded in the earlier years immediately 


preceding who suddenly had zeros in the HIS-20 


database and whose badges were not read. 


So it’s not clear that the badges of 


workers, that the workers whose badges were 


not being read had all uniformly low exposure 


potential. We looked at the case of one 


worker who was not in the HIS-20 database but 


whose case seemed to be quite important even 


though there’s no record in the HIS-20 


database of his file, and to bring up his 


sample. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

82 

MR. GRIFFON: Careful not to reference too 


specifically. 


DR. MAKHIJANI: Yes, I will not. 


MS. HOMOKI-TITUS: You might want to tell 


them somebody who --


DR. MAKHIJANI: Well, maybe, maybe not. 


Maybe not. 


MR. GRIFFON: Hold off on that. 


DR. MAKHIJANI: Yes, just hold off. I need 


to find the, yes, here. 


This person is listed as a non-


plutonium worker so he would fit into the 


general description of workers who were 


covered by the non-reading of badges, but 


actually worked in a lot of different areas. 


And so there’s the question of whether the 


workers who are described and officially 


assigned to non-plutonium areas were more 


frequently also working in plutonium areas. 


Also, we found quite significant, more 


than the ten percent limit doses recorded in 


every year for four years prior to the, prior 


to 1969. And then the badges were not read in 


1969. So this is a sort of a particular case 


and NIOSH has the data, claimant numbers and 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

83 

all of that information on this particular 


person. So that example actually raises a lot 


of different questions about job assignments 


as they are in the, as they actually happened 


compared to the policy of whose badge was not 


being read in 1969. 


MS. MUNN: Arjun, what, do you have the 


figures post-1969 for the same individuals? 


DR. MAKHIJANI: We do. 


MS. MUNN: And do you see better comparisons 


between the post-’69 and the pre-’69 figures 


such that you can, so that you are convinced 


that there was not likely a change in their 


work history during that particular period? 


DR. MAKHIJANI: We looked at people whose 


work histories did not change over certain 


periods of time prior to and after 1969, and 


maybe Kathy can elaborate on what I’m saying. 


And part of the reason for the concern is both 


immediately prior and immediately after some 


of the people whose badges are not being read 


do show non-zero doses. 


MS. MUNN: The static is back. 


MR. GRIFFON: Yeah, can I ask everyone on 


the phone, I know this is kind of a hassle, 

1 

2 

3 -- 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

84 

but if everyone could just hang up and redial 


back in. And we’ll pause for a minute and let 


UNIDENTIFIED (by Telephone): I think 


someone out there may have a Blackberry, and 


they need to disable that. That’s what the 


static is often associated with a Blackberry 


trying to pick up mail from the server. 


That’s what it sounds like to me. 


DR. WADE (by Telephone): I’m going to leave 


you now, too, Mark. I wish you well. 


MR. GRIFFON: Lew, thanks. 


MS. DeMERS (by Telephone): Wanda, this is 


Kathy. Arjun is right. We selected 


(unintelligible) table -- can you guys hear 


me? 


MS. MUNN: Yes, we can. 


MR. GRIFFON: Yeah, we can hear you. 


DR. MAKHIJANI: Be careful, all right, 


Kathy? 


MS. DeMERS (by Telephone): -- so that they 


had the same job title before 1969 and then to 


1970, and they were also assigned to the same 


area. 


MS. MUNN: Yeah, okay, I just, I understand 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

85 

that consistency. It’s just it’s difficult 


for me to not expect that there would have 


been some change in the way operations were 


conducted for awhile after that major fire. I 


would just assume that a lot of people, even 


though they went back to their former jobs 


afterwards, would somehow have been in some 


other part of the site doing some other kinds 


of work for a short period surrounding that 


massive incident. I don’t know how we could 


show that, but you’ve answered my question, 


thank you. 


MS. DeMERS (by Telephone): This is Kathy. 


Remember that we’re talking about uranium 


workers here. And the only shift they would 


have was to the plutonium area. We’re 


actually going from an area that’s supposed to 


be lower exposure to higher exposure. 


MS. MUNN: Except that the plutonium had all 


been taken out, and so it’s a different 


ballgame. But I understand and my question 


has been answered. Thank you. 


MS. DeMERS (by Telephone): One thing I 


would like NIOSH to provide to us is some sort 


of actual indication that the doses dropped in 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

86 

the 777 service area after the fire because 


we’re talking about that, but we haven’t seen 


anything like a survey report particularly on 


the external dosimetry or anything like that 


that did occur. 


MR. GRIFFON: Okay, we’ll go back to that, 


but let Arjun finish up his report. 


DR. MAKHIJANI: Let me just finish up the 


conclusions about 1969 data integrity and 


where we wound up. 


So there are four major bullets of 


issues that arise in relation to data 


integrity in the 1969 investigation. Not 


reading badges, not consonant with sound 


practice and throwing away the badge after a 


few weeks converted a problem of unsound 


practice to a problem of data integrity 


because it cannot now be verified as to what 


the doses were and whether the assumption of 


lower exposures was valid. 


We tried to examine that in other 


ways, and we would have definitely had some 


questions about whether that assumption was 


generally valid for the people whose badges 


were not read. There are indications that it 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

87 

was not. 


Non-reading of badges appears to have 


been done with the intention of minimizing 


work, but there’s some indication that this 


was, at least for some workers, an erroneous 


belief and notably for shallow dose. The 


entry of zeros in regard to the entry of zeros 


in some data records when badges were not read 


is a data integrity question about data 


recording practices for as long as that 


practice went on. 


And we have some question whether it 


was initiated as a de facto practice without 


being declared before 1969. And it was there 


definitely in ’69, continued into 1970, and 


when exactly it was stopped is not clear as 


we’ve discussed before. And we have some 


examples of workers whose badges were not read 


whose formal assignment did not include 


plutonium areas who did work in plutonium 


areas. 


And there’s also the case of one 


worker who was involved with the fire who 


apparently, whose badge was not read. So 


there’s that problem that also arose in our 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

88 

survey. 


MR. GRIFFON: The one with the fire, it was 


a response capacity? 


DR. MAKHIJANI: Yes, in a response capacity. 


MS. DeMERS (by Telephone): Now, he was a 


fireman who fought the fire. 


DR. MAKHIJANI: Yeah, that’s what I said. 


So that’s why I said in a response capacity to 


the fire. 


MR. GRIFFON: Apparently, I see Brant maybe 


not agreeing with that. 


DR. ULSH: Well, I don’t agree or disagree. 


What I need to check though, I think the 


report says fire suppression. And we do know 


that there were people, and I don’t know if 


this applies to this individual or not, there 


were people who were involved in fire watch, 


fire suppression, who never went in the 


building at all. And I don’t know if this is 


one of those people or not. What we have 


heard from the people who were involved in the 


immediate aftermath of the fire was that only 


the professional staff went in, and they, 


after the fire, and they were monitored. So I 


don’t know. We’ve got to look a little closer 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

89 

on this one. 


MS. DeMERS (by Telephone): Do you want me 


to respond to that? 


MR. GRIFFON: I don’t know if it’s worth it 


at this point. There’s just a question there 


I think. Let’s leave it at that for now. 


DR. MAKHIJANI: And as before in the 


completeness investigation, we haven’t kind 


of, we felt that our instruction from the 


working group was to examine the issue to see 


if there was one, and that the detailed work 


of resolving it was NIOSH’s work and not our 


work. So we haven’t tried to track all these 


issues down to the last, and so it may well be 


that there’s a good explanation or not. And 


that we’ve left up to NIOSH. 


The conclusions in regard to the 


overall situation with the 1969 data is that 


overall the gaps don’t appear to be related to 


the fire although there’s some fire-associated 


questions but largely to this policy of not 


reading badges. And there is questions of 


data integrity and also about how the coworker 


models are going to be developed with uranium 


workers which we also raised earlier, the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

90 

complication with 1969 compared to the 1950s 


just to be clear. 


In the 1950s there was a policy of not 


badging a certain group of workers, and they 


were not badged, and there was no data 


integrity problem there. Here there were 


badges that were issued -- maybe I can just 


talk very loudly, overcome the static. 


Here there were badges that were 


issued that were not read and were 


subsequently thrown away so this is a much 


different issue. And that to some extent at 


least corroborates the petitioners that there 


were zeros entered into some dose records when 


the badges were not being read. That’s an 


issue that’s been raised in the petition, and 


while in the earlier period we did not find 


that, it was simply people who were not 


badged. Here there is a more substantial 


issue of data integrity. 


MR. GRIFFON: Can I ask, Arjun, did you, I 


know you were focused on the ’69 period, did 


you find this practice in other time periods 


beyond, I think you said ’70 there might have 


been some, too --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

91 

DR. MAKHIJANI: It goes into 1970, but we 


did not actually go into individual dose 


records --


MR. GRIFFON: -- prior to or after that? 


DR. MAKHIJANI: Well, there’s the one case 


that we have of a person with 11 years of 


blank records from ’63 to ’74 that came up in 


the data completeness question in the very 


first set that we examined. Actually, I think 


it was the very first one that I looked at 


which caused me to sit up. And --


MR. GRIFFON: And in that instance there 


were blanks all through the hard copy file, 


but the database had zeros for that --


DR. MAKHIJANI: Yes. 


MR. GRIFFON: -- those 11 years? Or do you 


know? 


DR. MAKHIJANI: Well, I don’t know that the 


database has zeros because I’ve not tracked 


the individual’s HIS-20 file. I know that 


this was a worker that was supposed to be 


badged because they were a prime contractor 


worker. NIOSH said in a working group meeting 


that they were not badged, but we have no 


documentation of that. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

92 

MR. GRIFFON: Well, we have no policy sort 


of thing to see, right, right. 


DR. MAKHIJANI: And so they may have been 


issued a badge, and there may be no readings. 


Or they were not issued a badge. But in both 


cases it kind of raises a pretty big question 


of was there really ever a universal badging 


policy in place for prime contractor workers 


and who was not badged, if NIOSH’s statement 


is to be taken at face value? Or if not, was 


this policy initiated more formally in 1969 of 


not reading large numbers of badges to save 


work, actually de facto introduced at some 


earlier time and then formalized in ’69, and 


then stopped at some time maybe when TLDs were 


introduced. It’s unclear. There are a lot of 


questions there. We can make some guesses, 


but --


MR. GRIFFON: Yeah, let’s not make guesses. 


Brant, I’m sure you pretty much --


That’s it, Arjun, for a summary? 


DR. MAKHIJANI: (no audible response) 


MR. GRIFFON: Go ahead, Brant. 


DR. ULSH: We certainly agree that there are 


more zeros in ’69, and it looks like from the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

93 

figures that SC&A has put in their report, 


possibly into ’70 as well. As Arjun mentioned 


when this issue was first brought to our 


attention, we considered a number of 


hypotheses, the first of which, I mean the 


most obvious of which would be some connection 


with the fire. And we eventually determined 


that it was not related to that. 


MS. MUNN: Static again. 


DR. ULSH: But I want to be clear. The 


population that this issue affects, this 


policy of not reading the badges of people who 


were in the non-plutonium areas, there’s 


another criteria in there who were on 


quarterly badge exchange cycles. Now these 


were people who were judged by the health 


physics staff to be at low exposure potential. 


And we can discuss whether or not they could 


make that determination adequately. 


But we are not talking about all 


people who are in non-plutonium areas, only 


those who are on quarterly. There were also 


people who were on monthly exchange cycles, 


more frequent than quarterly. So the issue 


that we have here is for the people who are on 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

94 

quarterly, and that’s the cohort that was 


judged to be a low exposure potential. 


Now we also have discussed in the past 


that in terms of 1970 there was a strike that 


occurred in the summer of 1970, lasted for 


about 70 days. And also you have the ’69 


fire, of course, which disrupted production in 


the highest exposure areas of the site. It 


took the people onsite who, in general, got 


the highest exposures and put them in a non-


production role in some cases. So you would 


absolutely expect to see higher frequencies of 


zeros. That’s not surprising. 


Now in terms of this policy, you know, 


it’s certainly not the way I would have done 


things, but that’s not really the question. 


The question is does it prevent us from doing 


dose reconstructions with sufficient accuracy. 


Now, I don’t want to commit to a work 


around on this until we finish our analysis, 


but one thing that I would like to put on the 


table for the working group and SC&A to 


consider is that given that we have a cohort 


of people who were judged by the health 


physicists at least to be at low exposure 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

95 

potential, what would be, I mean, if we decide 


that those people, that cohort of people, the 


quarterlies, could not be used because we 


can’t differentiate real zeros from really 


unmonitored doses that were artificially 


converted to zeros. 


If we decide at the end, and I’m not 


saying we are, but if we decide at the end 


that that population of data is corrupt, and 


we can’t use it, we can’t rely on it, what 


would be the effect of not using that data? 


Of taking the quarterly badge exchange cycles 


and not considering them? 


Well, if you think about --


MS. MUNN: Static again. 


DR. ULSH: I hope you’re talking about the 


reception and not me. 


MS. MUNN: No, but that is a Blackberry. I 


do wish you’d take your PDA and place it 


elsewhere. 


DR. ULSH: So if you look at the 


distribution of coworker, the distribution of 


the population of doses that you have, and you 


take out the people who are on quarterly, what 


are you doing? Well, in general, and I’m not 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

96 

saying in every single case but in general, 


speaking from a population standpoint, what 


you’re doing is you’re lopping off the lower 


end of your coworker distribution so that when 


I pick a 95 percentile value or a 50 


percentile value or whatever it is that we 


pick, the value that I pick without the data 


would be higher than the value I would pick 


with that data in there. 


So in effect at the end of the day, if 


we say this data’s no good, we take it out. 


That’s a claimant favorable thing to do in 


terms of assigning coworker doses to 


unmonitored people. And that’s what we’re 


talking about here. These people whose badges 


were not read, in fact, they’re unmonitored. 


That’s what they are. They wore badges, but 


those badges weren’t read. So it’s the same 


as if they weren’t wearing them. 


And if you look at the coworker data 


that, the values of coworker data that we are 


proposing, that we have in our TIBs for 1969, 


it is far, far, far higher than you see for 


people, you know, the lowest exposure people 


on the site. So I’m not committing to that 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

97 

approach. I’m just saying that when you think 


about this in terms of what is its relevance 


in terms of an SEC consideration, that is 


something that we should think about. 


Now one of the conclusions that SC&A 


has in their report here I have to express 


some caution about. It says while the non-


reading of badges may have been done with the 


attempt to minimize work -- well, let me just 


read it in total. 


“While the non-reading of badges may 


have been done with the intent of minimizing 


work related to reading badges of workers 


judged to have low exposure potential, the 


facts relating to at least some non-plutonium 


work indicate that this was an erroneous 


belief, notably for shallow dose.” 


Now am I correct in assuming that that 


refers to the uranium foundry workers or does 


that refer to something else? 


MS. DeMERS (by Telephone): No, it’s not 


related to them. 


DR. MAKHIJANI: Right, Kathy. Go ahead. 


MS. DeMERS (by Telephone): When I went and 


investigated gaps, I did a spread from various 

1 

2 

3 

4 

5 

6 

7 

8 -- 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

98 

buildings and just for example, there’s a --


MS. MUNN: Static, there’s static out there. 


MS. DeMERS (by Telephone): It’s probably 


coming from my phone. 


MS. MUNN: Well, I hope not. We need you. 


MS. DeMERS (by Telephone): Just to give you 


an example, there’s an administrative building 


MR. GRIFFON: A little louder if you could, 


Kathy. 


MS. DeMERS (by Telephone): There’s an 


administrative building, 111, and normally 


they’re not routinely in the field, but they 


do periodically go into the field. And in one 


case on our table we have an industrial 


photographer. Well, he happened to have 


photographed all those wonderful pictures of 


the fire, and subsequent pictures of the 


cleanup. So there’s an example where, no, 


they’re not coming from the foundry, they’re 


not coming from the immediate uranium area, 


they’re just a professional that had the 


opportunity to intermittently go out into the 


field. 


Some of the people we looked at were 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

99 

machinists. 


MR. GRIFFON: Machinists. 


MS. DeMERS (by Telephone): Some of them 


were equipment operators. We have an 


electrician. 


MR. GRIFFON: Okay, so it’s broader than the 


uranium and foundry workers is what you’re 


saying. 


MS. DeMERS (by Telephone): Right. 


DR. MAKHIJANI: Mark, the data are in your 


write-up in Table X-4, and it does show a 


sampling of different buildings, different job 


types. They are largely from Building 444, 


but there’s also the 881 and 883 and 111, 331. 


And you see quite large beta doses, relatively 


speaking, in at least two, three, four cases. 


And these are all cases in the last, where 


these beta doses are recorded in the last 


quarter of ’68. And in all these cases if you 


look at the first quarter 1969, the badges 


weren’t being read. 


DR. ULSH: Okay, now I understand what 


you’re saying. Okay, we’ll take a closer look 


at the Table X-4. Arjun, I’m looking at the 


de-identified version. I think you guys also 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

100 

sent us one where it does identify these 


individuals, right? 


DR. MAKHIJANI: Yes. 


Kathy, did we send all the claimant 


numbers -- I do not remember now -- to NIOSH? 


MS. DeMERS (by Telephone): If you don’t 


have them, I can pull those up. 


MR. GRIFFON: We’ll make sure it happens if 


you don’t. 


DR. MAKHIJANI: I don’t know if we actually 


in this case sent you a version with claimant 


numbers. At least I don’t remember seeing one 


with claimant numbers. 


MR. GRIFFON: And this report from what I 


understand is still under Privacy Review. Is 


that correct? 


DR. ULSH: I think, Joe, is that what you --


MR. FITZGERALD: Yeah, that’s my 


understanding. The copy I have has a notation 


that it’s subject to Privacy review, and I 


think we sent it to you and Brant back in the 


10th of January. I think that’s the only one 


that hasn’t come back. Now there’s been so 


much going back and forth that I think we just 


need to validate that that’s where it stands. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

101 

But I believe that’s where it is. 


MR. GRIFFON: I just want to, again, and 


this goes for all the, those four items that 


we’ll discuss the rest of the day, that we’ll 


commit to getting these to the petitioners’ 


interested parties as they’re cleared for 


Privacy concerns. 


DR. ULSH: So like the other sections of 


SC&A’s report, we are still reviewing this. 


And this is one where in contrast to some of 


the other sections, I think SC&A sees a 


potential at least for SEC implications. I 


don’t see any disagreement. 


DR. MAKHIJANI: Well, this is, of course, up 


to the Board. We did raise the question about 


dose reconstructability given the state of the 


data for this group of workers. But there’s 


also that to some extent we raised the 


question also in regard to some workers in the 


1950s that it’s not a separate question that 


the dose reconstructability for 1950s is 


settled for the uranium workers. 


DR. ULSH: Well, where I’m headed with this 


is that this is one where since there’s at 


least some belief that there might be SEC 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

102 

implications, that this is one that we’re 


going to focus on more than some of the other 


ones like, you know, we’re going to get into 


log books and whatnot. This would be a higher 


priority for us. 


MR. GRIFFON: It’s certainly a high priority 


I think. All of the data included in this 


section I think is a high priority and with 


’69 maybe being the highest of that. 


DR. ULSH: So yeah, we’re going to be 


preparing a detailed response. We’ll look at 


each of the individual cases here. And like I 


said, the point that I just want to make is 


that we are not talking about all 1969 data. 


We are talking about quarterly data for non-


plutonium areas. 


DR. MAKHIJANI: This is correct that I 


should have mentioned that we’re talking about 


quarterly data so that I omitted that fact. 


And I also omitted something else which is 


that there were some badges that were 


contaminated after the fire. And both during 


worker interviews and in some documentation 


it’s indicated that some badges at least were 


thrown away. Not again, for nefarious 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

103 

purpose, but simply because you don’t want to 


contaminate the reading equipment and so on. 


But some badges of people involved in the fire 


would have been thrown away. So some of the 


zeros may be related, or gaps, may be related 


to that. 


MR. GRIFFON: Did you do follow up to see 


because the suggestion I saw in some of the 


log books was that badges were destroyed for 


those contamination reasons, right? 


DR. MAKHIJANI: Right. 


MR. GRIFFON: But I thought I saw, at least 


one of the log books suggested that health 


physics assigned or assigned a dose to the 


individual --


DR. MAKHIJANI: Kathy would have looked at 


that. 


MR. GRIFFON: -- and I don’t know if you 


cross-walked any of those. 


DR. MAKHIJANI: Kathy, did you? 


MS. DeMERS (by Telephone): I took all of 


the discussion of badged individuals and 


included them in the log book review. 


Unfortunately, only two of them had claimant 


files. And those two, if I remember, did not 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

104 

have the dosimetry investigation in their 


file. 


MR. GRIFFON: Did they have anything in 


their record, in their recorded dose for that 


quarter or year? That may be a little 


inconclusive there because they may have had 


other periods where they had monitoring and 


the whole year would add something. 


MS. DeMERS (by Telephone): I don’t think we 


were able to define the particular badge 


period. 


MR. GRIFFON: Okay, maybe we’ll catch that 


in the log book stuff, too, but I just 


wondered if any of that had been tracked 


through. 


DR. MAKHIJANI: Kathy would have looked at 


this. I certainly did not. 


DR. ULSH: Well, there were a couple of 


points there that I can maybe speak to now. 


All of our indications are that when people 


went in immediately after the fire to assess 


the situation and to remove the plutonium, 


that those people were fully suited and double 


badged. So I mean, it is certainly possible, 


and I think it was even probable, well, I 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

105 

don’t think there’s any question that on 


occasion badges became contaminated and were 


disposed of. And those are noted in 


Kittinger’s logs and the notation said that 


that was witnessed by other people. 


Now in terms of the lack of 


investigation reports, I don’t know. I’d look 


at the agenda again. We may get to that some 


other place on the agenda, but as we’ve 


discussed in the past, you would expect to 


find the abbreviated or extended dosimetry, 


sorry, dose reconstruction investigation I 


think is the title of it, in the later 


periods. You know, we provided those 


procedures. In the earlier periods you would 


not necessarily expect to see the same kind of 


documentation. 


MS. MUNN: Worse than static. 


DR. ULSH: That’s not to say though that 


investigations weren’t done, just that they 


didn’t have a formal mechanism like they did 


in the ‘90s, I don’t know what the time period 


was, where they had a standard form that they 


wrote up the investigation on. We have seen 


from various documents that I believe Kathy 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

106 

might have supplied, although don’t hold me to 


that, there were some individuals where, just 


for example, the, I think it was the neutron 


badges were higher than they expected. 


And it clearly indicates that that 


situation was investigated and that doses were 


assigned. So I mean there are situations that 


indicate that investigations were done. It’s 


just the documentation is not the same as it 


was in the ‘90s. 


MR. GRIFFON: I guess that was my point is 


that the log books seem to suggest that they 


did attempt to assign some dose. And if you 


cross-walk that and see there was a blank then 


that might be an issue. But if there’s some 


dose recorded --


DR. ULSH: Right. 


MR. GRIFFON: -- then, you know, it might 


be within their procedures. 


DR. ULSH: Well, we interviewed a couple of 


people on this, one of whom was, okay, I 


pause, but I think that’s okay, one of whom 


was Bob Bistline who was the site expert that 


SC&A employs, and he strongly disagreed with 


the suggestion that they would have just 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

107 

assigned zero in a situation. They always, 


okay, I don’t want to say always again, but it 


was the policy to investigate situations where 


badges were suspect or had to be discarded. 


So I mean, we’ve heard that from a number of ­

-


MR. GRIFFON: Well, I’m just simply asking 


the simple question, these log books actually 


have specific badge numbers, and if you can 


cross-walk them that may actually strengthen 


that. 


DR. ULSH: Do I hear an action item? 


MR. GRIFFON: No, but I think we might pick 


that up in the log book analysis. I think 


it’s already in that so that discussion --


Kathy, unless you want to, some of 


this I think gets into our log book 


discussions. 


MS. DeMERS (by Telephone): Actually, in all 


the entries we pulled out of the log books I 


think there was one that indicated that there 


was an investigation in the field. 


MR. GRIFFON: Okay, but again, we don’t know 


if, the documentation process in the early 


years versus the later years, I mean, I think 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

108 

we can discuss this further. I think I’d like 


to save it for the log book because I know we 


have it in there. 


I mean, I guess for the ’69 question 


really, you’re looking into this, the only 


thing I would say is that we keep saying ’69 


and I guess the thing that jumps out at me in 


this discussion is the blanks and having zeros 


entered in the HIS-20. And it brings up this 


whole question of the integrity of the HIS-20 


database period. 


And I think to the extent we can, and 


this might involve SC&A, I’m not sure who 


should have this action, but I know out of 


those other cases it seems to me that it 


wasn’t only necessarily a ’69 issue. Or you 


had that one example of the first twelve cases 


where you had 11 years, but you didn’t then 


look and see if that carried through to the 


database if the blanks in that individual’s 


records carried through to zeros in the 


database. 


And I think that, you know, I have a 


question in my mind is was this just in ’69 


where you had some blanks inadvertently or for 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

109 

whatever reason entered as zeros in the 


database or is that in other time periods as 


well. And maybe all of this can be resolved 


like you said. I hear your option about 


potentially you could just drop this quarterly 


and that may --


DR. ULSH: And this ties back again to that 


question you asked earlier, Mark, about when 


did that non-read policy end, right? 


MR. GRIFFON: Right, partially, yeah. 


DR. ULSH: If that question could be 


answered it might put a --


MR. GRIFFON: Shed some light on all of 


this, yeah. 


MS. DeMERS (by Telephone): I have a 


suggestion. 


MR. GRIFFON: But it also that one example 


is prior to ’69, too, which is a little --


DR. ULSH: This is the individual with 11 


years, the administrative assistant? 


MR. GRIFFON: Yeah. 


MS. MUNN: Kathy’s trying to say something. 


MR. GRIFFON: Go ahead, Kathy. 


MS. DeMERS (by Telephone): I have a 


suggestion on when the policy may have ended, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

110 

and you can check this out. The uranium areas 


were among the last people to be assigned the 


TLDs towards the end of ’70, and that policy 


may have ended with the assignment of TLDs to 


different groups. 


MR. GRIFFON: Yeah, I think Brant kind of 


suggested that earlier, so if we can, you 


know, have that may, but then that raises the 


question of if individuals have blanks beyond 


that, why? So it’s the same I’ve raised as 


before. That if the policy were short term it 


may explain this spike in the number of zeros 


for that one year, but it doesn’t explain the 


gaps or these blanks in other years beyond 


that time period. 


DR. ULSH: What I would suggest to you, 


Mark, is that we get back to you after we have 


looked at those TLD worksheets or results, TLD 


results, and see if we see the same pattern. 


Then we can go forward. 


DR. MAKHIJANI: Mark, I think maybe two 


action items and probably for NIOSH, but two 


action items that would help in clarifying 


these issues at least. If these same 


individuals that we’ve looked at could be 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

111 

tracked into the TLD period and before 1969, 


that would be very useful to see what kind of 


records they have and whether there was a non-


reading policy. 


And in regard to that one case with 11 


years of blanks, if we could look to see if 


that person is in the HIS-20 database and what 


might be entered there. And similarly for the 


cases that have gaps in the ‘50s where there 


were no badges issued whether who was there in 


the HIS-20 database and what’s in the HIS-20 


database. That’d be obviously important 


because of its use for the coworker model. 


So I think that would clarify at least 


some of the issues that are on the table in 


regard to what’s in that database and the 


status of these individuals and maybe when 


these policies began. I’m not sure that it 


will, but it may. 


MR. GRIFFON: And I think this will be, 


probably you can roll this into your response 


to these, the first two items anyway, so that 


makes sense.


 MS. JESSEN: Three items. Weren’t there 


three? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

112 

MR. GRIFFON: Were there three? 


DR. MAKHIJANI: Maybe there were. 


MR. GRIFFON: Two and I thought you rolled 


into a third. Should we restate those? Just 


for clarity restate those, Arjun. Track the 


individuals found in your ’69 review, right, 


back in the prior years and future years? 


DR. MAKHIJANI: And future especially if 


there’s a clear suggestion that their TLDs 


were being read then we will have a pretty 


good answer about the ending date for this 


policy. 


And then there’s the one case of the 


administrative assistant --


MR. GRIFFON: Yeah, 11 year case, yeah. 


DR. MAKHIJANI: -- and then there’s the gaps 


from the data completeness, so those are 


three, three things. 


MR. GRIFFON: The last one is the gaps from 


the --


DR. MAKHIJANI: Gaps from the data 


completeness, whether they’re zeros in the 


HIS-20. 


MR. GRIFFON: From your ’52 case review, 


right? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

113 

DR. MAKHIJANI: Yeah, from the case reviews 


in the first paper that we discussed. 


MR. GRIFFON: Anything else on ’69 because I 


think we’re ready to --


DR. MAKHIJANI: I think that’s it. 


MR. GRIFFON: -- break for lunch. 


Anything else, Brant? 


Okay, I think we’ll break for lunch 


and come back at 1:30, and we’re off the 


record now. 


(Whereupon, a lunch break was taken at 12:27 


p.m. and the meeting resumed at 1:35 p.m.) 


MR. GRIFFON: We’re reconvening the work 


group meeting, the Rocky Flats work group 


meeting, and I think we’re on to item three. 


Now, I did have a follow-up question 


on the first two items we covered, the data 


completeness item, specifically, I know that 


we talked about the policies around the 


external monitoring program. And I think it 


might be worth, at least for me I would like 


to see if you can incorporate into your 


response something about the internal 


monitoring requirements and how they pertain 


to the gaps or non-gaps in the SC&A report. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

114 

For instance, if you have someone that 


has annual plutonium samples, but the policy 


said for that building they should have been 


on quarterly or something, you know. I don’t 


think that they got into that detail, but I 


think that might be, you know, if we’re 


looking to see if policies are consistent with 


what we’re finding in the data, I think that 


might be useful. 


I’m still getting that echo. I was 


hoping that would go away. 


DR. MAKHIJANI: And, Mark, as I said in my 


introduction to the completeness thing, we 


used a very broad screen and besides the time 


periods and the intra-year data, within the 


year results of the radionuclide question. So 


there, you know, this is just one aspect of 


completeness that we did. 


MR. GRIFFON: And I should also say that I 


don’t know if this is a complete new sub-


action on this item or anything because it 


may, I’m not, I was going to go back and I 


didn’t get a chance to go back to the internal 


dose site profile so you may have laid a lot. 


I think you have some of that 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

115 

information in there on who, what type of 


monitoring was done, what time periods and 


things like that. So some of that may be 


there already. I’m not looking to recreate, 


you know, if you already have it there, it’s 


fine. Just maybe bring it to our attention. 


MR. BUCHANAN (by Telephone): Mark, this is 


Ron Buchanan. Can you hear me? 


MR. GRIFFON: Yes, go ahead, Ron. 


MR. BUCHANAN (by Telephone): One thing that 


I have suggested, and I don’t think that 


anyone’s ever done is on the ’69-’70 that if 


we go back and look at the internal dose data 


and see if it has the same spike and number of 


zeros, it might shed a little light on why 


these occurred in external doses. 


MR. GRIFFON: Yeah, I don’t know that we 


looked at that. I’m not, I don’t think that’s 


been raised before. 


MR. BUCHANAN (by Telephone): I don’t know. 


It just might shed some light on why there was 


or wasn’t a reason for the increase in the 


zeros and see if the same thing happened in 


the internal doses. 


MR. GRIFFON: How would that shed some 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

116 

light? 


MR. BUCHANAN (by Telephone): Well, if we’d 


seen the same thing. If we didn’t see that, 


well then we would see that these people were 


being monitored and there’s something wrong 


with the external dose. But if there was the 


same scenario in the internal dose then that 


would probably shed a different light on why 


this was being done. 


MR. GRIFFON: It may. It may I guess I 


would say for these 20 or so cases that were 


brought up for the ’69, is it 20 individuals? 


DR. MAKHIJANI: The 19 individuals who had 


the zeros in the HIS-20 database, and then 


there’s the one individual that’s not in the 


HIS-20 database. So there are 20 in all. 


MR. GRIFFON: See, I’m not sure it 


definitively answers, addresses any questions 


because they, I think Brant was suggesting 


earlier that it was possible that they were on 


some sort of internal program but not required 


to be badged or didn’t read their badges. I 


don’t know. 


DR. ULSH: Yeah, I mean, keeping in mind 


that I think we’ve agreed, SC&A and NIOSH have 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

117 

agreed that it’s at least consistent with this 


badge non-reading policy to see this spike in 


zeros. But that only applies to film badges. 


That doesn’t tell us anything at all about 


what they did with internal. So I don’t know 


if you would expect to see a spike in zeros or 


not. I don’t know. 


MR. PRESLEY: You’d almost have to have the 


same number. You’d have to be looking at the 


same people, wouldn’t you? 


MR. BUCHANAN (by Telephone): What I was 


thinking is if you had an overall increase in 


the internal dose not being monitored during 


’69 and ’70, that might lend itself to say, 


okay, we didn’t have people in radiation areas 


so we weren’t badging them where we had a lot 


of zeros. Internal monitoring remained a 


constant from ’68, ’69, ’70, ’71 and such, 


then we’d say, well, these people were being 


monitored internally so that we know they were 


probably working in radiation areas is what I 


was thinking. 


It might help us sort out whether 


these people were not badged but had about the 


same jobs or whether they had different jobs 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

118 

during this period of ’69 and ’70. And 


internal dose would show a difference during 


those two years also if they had a change in 


function. 


MR. GRIFFON: I think I would leave that as 


a suggestion for SC&A to consider in how they 


answer the question of the ’69, you know. I’m 


not sure it’s going to be definitive though, 


that’s my --


DR. NETON: This is Jim Neton. I think if 


they took people off external monitoring at 


the uranium facilities is my understanding 


because the dose potential was low for 


external. But as we learned at Y-12, the 


internal potential was really the hazard from 


working with uranium. And so it would be 


totally consistent to have a routine 


monitoring for internal continual all along 


and drop the external, and wouldn’t really 


tell you anything. 


MR. GRIFFON: At least it could be, so it’s 


not definitive. 


DR. NETON: Wouldn’t cut it one way or the 


other I don’t think. 


MR. GRIFFON: I think it might be 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

119 

inconclusive but I’ll leave that to, you know, 


in your response if you want to consider that 


suggestion. I don’t think it, at least in my 


view, I don’t think it’s an action right now. 


MS. DeMERS (by Telephone): This is Kathy. 


In my X-2 Table that I have in the 1969 


report, I did give you a yes or no answer as 


to whether they were monitored May 11th through 


the end of ’69 both in vitro and in vivo. 


MR. GRIFFON: Okay, so maybe consider that 


table that SC&A’s provided. Thank you, Kathy. 


COWORKER MODELS
 

Okay, can we move to item three, 


realizing that we’re in the afternoon crunch 


as usual. I do want to stick to closing by 


5:00, really. I know a lot of people have 


planes to catch, and it is a Friday. 


So we’ve got coworker models here, and 


I think, and I’m not sure how far we can go on 


this, but it comes up in, the way I bring it 


up here is in the context of the data 


completeness related to the two prior items 


and Brant alluded to this a little bit with 


the quarterly badging question and the 


possibility of looking into that and maybe 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

120 

modifying the coworker model, not committing 


to it as you said, but the possibility. 


But the question of why it was here on 


the agenda was basically to say, you know, and 


I don’t think we’re really here yet because we 


don’t have, you haven’t had a chance to fully 


investigate all of SC&A’s report. But if 


there were gaps, as it was raised before in 


the meetings I think Jim brought this up, too, 


that if, in fact, we do find these blanks or 


gaps and do the coworker models or can the 


coworker models adequately account for that or 


be used to reconstruct doses for those gaps. 


And I think we were thinking both internal and 


external so I just put coworker models here. 


The other reason I bring this up here 


is this question of pedigree that I’ve brought 


up through numerous meetings of the discussion 


of the coworker models and the HIS-20 versus 


the CER and then we have this question, and 


I’m not sure we’re ready to discuss this 


because you’re still reviewing these other 


reports, but the question of if you have 


blanks that were turned into zeros it raises 


some questions, at least in my mind, of how 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

121 

good is this database. How reliable is this 


database for use as coworker models. 


Now we have analyzed this in several 


different ways. You’ve looked at CER versus 


HIS-20 and basically on the internal side you 


gave us a report that concluded that the 


intakes would be very similar, equivalent, I 


guess, over all years. So that that was sort 


of a bottom line question was even if there’s 


differences, the bottom line is we get similar 


intakes. 


We also have the Donna Cragle 


analysis, and I’m laying these things out so 


that as we go forward we address these. That 


report, that Donna Cragle analysis, that 


looked into the question of CER versus HIS-20, 


and to me, this raised a problem in my mind 


when you look down the years and there’s a 


table in that report that says the data over 


each year and how, and I originally in the 


matrix defined it as large discrepancies. I 


think there are some pretty large 


discrepancies in a number of data points just 


looking at the number of data points. 


And so the question is if you’re 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

122 

missing two or three thousand data points, but 


at the end of the day the intakes are the 


same, I think we need to look at that closer I 


guess is my challenge going forward as we 


consider the data completeness if we realize 


the coworker models are going to be into play 


more significantly for the Rocky claimants, I 


think we need to consider those pieces again 


and make sure that we’re comfortable with 


them. You know, SC&A but also ultimately the 


Board I guess, that we’re comfortable that 


they’re going to be adequate. 


And I think there’s a lot of ins and 


outs on this. I’m not sure. I’m trying to 


remember the original analysis, but the, 


comparing the CER and the HIS-20 when it 


concluded that the intakes were the same, I 


think we want to see what exactly, you know, 


maybe look closer at that and see what exactly 


that --


MR. FITZGERALD: And we haven’t done that 


yet. 


MR. GRIFFON: Right, right, I don’t think 


that SC&A dug into that. 


MR. FITZGERALD: No. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

123 

MR. GRIFFON: And it’s important to again 


emphasize the history of this that we kind of 


didn’t look into the coworker model so 


strongly because we were basically under the 


impression that very few claimants were going 


to require coworker models to reconstruct 


their dose. So I think this is kind of queued 


up depending on the completeness analysis, and 


also depending on, I mean, I have kind of a 


follow-up question for NIOSH. 


I think that since these TIBs have 


been published, the coworker TIBs, I think 


you’ve indicated that there were probably more 


claimants that might require at least partial 


use of these coworker models. And I don’t 


know if you have any sense of, because when we 


first talked it was a very small fraction that 


we thought, and now I think that might have 


changed or shifted or whatever. 


Do you have any sense now of, you 


know, because if it’s very few out of 1,100 or 


how many ever claimants, then I think we have 


to weigh this differently than if it’s a lot, 


right? 


DR. ULSH: I can’t give you exact numbers, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

124 

Mark. But what I can tell you is that, you 


know, and we talked, I don’t know, middle of 


last year at some point. I think at that time 


we only had just a couple, maybe two or 


something like that cases on hold because they 


needed coworker data to finish them. 


Now subsequent, and what I said at 


that time was that, at least I think I said it 


at that time, was that the need for coworker 


data at Rocky Flats is not zero, but it’s 


minimal compared to what you see at other 


sites based on what we’ve seen so far. Now we 


were only 700 out of a thousand cases. 


But subsequent to that the TIBs were 


published, the coworker TIBs, and what we have 


indicated is that after the publication of 


those TIBs, it’s not necessarily that the 


claims require the coworker data, it’s just 


that that might be the easiest way to do it. 


Now there might be other approaches available, 


but since the coworker TIB is available, and 


it’s easy to use, we use it. 


So I can pretty much say with 


confidence that the amount that those TIBs 


have been, the coworker data has been used has 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

125 

gone up since publication of the TIBs. I 


still don’t think that it’s a major usage 


compared, when you compare like to other 


sites, but I don’t have the numbers for that. 


I can get those kind of numbers for you. 


MS. MUNN: Mark, I’m not sure that I 


understand exactly what you’re asking here 


with respect to, I had been under the 


impression that once we had the new procedures 


put together that we were pretty close to some 


sort of usable data having compared these two 


databases and knowing where there were any 


discrepancies that we could move over from 


there. But am I understanding that you’re 


asking SC&A to do something specific now with 


this data comparison? And if so, I guess I 


need some clarification here. 


MR. GRIFFON: I’m asking SC&A, I don’t 


think, I think we had that deliverable with 


the analysis that concluded that the intakes 


from CER and HIS-20 were essentially the same. 


MR. FITZGERALD: That was Joyce’s work on 


the model cases that were --


MR. GRIFFON: No, no, no, that was --


DR. MAKHIJANI: That was NIOSH. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

126 

MR. GRIFFON: That was Lockamy’s, and I’m 


asking for them to, I don’t think that you’ve 


ever reviewed that specifically. 


MR. FITZGERALD: No. 


MR. GRIFFON: And I think we kind of let 


that go, and we’ve just, it’s been brought up 


again, and I just want to make sure that we 


all are in agreement with that conclusion 


that, in fact, you know, and also, it’s not so 


much, I think we’ve been through the coworker 


models, and I think SC&A’s pretty comfortable 


with the model itself. 


Now the question is the data that went 


into the model, so the construct they’re 


comfortable with, I think, it’s the data, 


whether the data is, you know, this goes back 


to this data completeness, data reliability 


question. This question that Arjun raised 


about blanks being put in as zeros. That 


certainly skews your data. And then on the 


other hand the use of the coworker model. How 


is it being used, implemented? 


That gets back to things that Jim 


brings up like are you, the 95th can bound, you 


know, but I don’t know that, so if they’re 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

127 

using the 95th in most cases then we’ll 


probably, you know, we have one level of 


comfort. If you start using the median, then 


you’re worried about these zeros probably a 


little more. I mean, there’s a bunch of sub-


questions there, I guess. 


MR. FITZGERALD: Where they’re coming at it 


from, I think you described it pretty well, 


coming at it from three different directions. 


Certainly looking at the concept itself, how 


the model’s constructed. We had quite a bit 


of discussions on OTIB-38, internal for 


example. I think we’ve satisfied that issue. 


We’re pretty far along on OTIB-58 with what 


Ron’s been doing with ORAU. 


The other aspect is we’re looking at 


the completeness issue which is kind of catch 


me up to the coworker review because again, we 


have to look at that first before we can judge 


that. Certainly, we talked about that. 


The third one we talk about in terms 


of application. Now you’ve got this model, 


you know, how’s it going to be applied. And 


we’ve actually got into that a fair amount. I 


think we had discussions on an issue-specific 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

128 

call that dealt with OTIB-38 and how it could 


be applied, question at 95th percentile, issues 


like that. 


But we’re also looking at questions 


such as, but on the application side I think 


we have started looking into that, had 


discussions on how the models would be 


applied. And certainly one issue since we now 


have, had OTIB-49, high fired, you know, how 


would OTIB-38 apply, certainly, in those cases 


as well. So we’ll look at the application. 


Those are the three facets. 


MS. MUNN: So for my benefit I guess what 


I’m trying to do is get my intellectual arms, 


as short as they are, around how large this 


issue is because I have some concern about 


this size, the magnitude, of the task we’re 


asking SC&A to perform here at this point in 


our deliberations. I just --


MR. GRIFFON: Well, right now I think it’s 


to review a report that was on the table a 


long time ago, but they didn’t, but we sort of 


didn’t say, it wasn’t a pressing action at 


that time. 


MS. MUNN: So you don’t see this as a big 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

129 

thing? 


MR. GRIFFON: No. 


MR. FITZGERALD: Well, it’s at the point now 


actually, we’ve been working at this for 


awhile on these other fronts, but we haven’t 


looked at that specific question, and we 


haven’t quite finished up with some of these 


others. But really, we’ve looked at the 


construct. We’ve looked at the data 


completeness. So we’re pretty far along. 


This doesn’t represent a new avenue per se. 


MS. MUNN: So we really wouldn’t be 


expecting this to be a long-term problem for 


you? 


MR. FITZGERALD: No. 


MS. MUNN: It’s an issue that we can hear 


back on fairly soon? 


MR. FITZGERALD: I would think so, yes. 


This isn’t the first time we’ve looked at HIS20 and CER, but we did it in the context of 


what work that Joyce has been doing. So we 


need to look at it a little broader than that. 


MR. GRIFFON: I guess for me, you know, 


another troubling piece of this for me is that 


if you, I mean, every time I seem to look at 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

130 

this I find discrepancies between these two 


databases, and not one or two or 20 or 30 data 


points. It’s extensive. And to me you start 


to wonder. I wonder about the validity of 


either one. And we’re looking at it saying, 


okay, we’re getting a similar result at the 


end of the day so don’t worry about it, you 


know? It makes me a little uneasy of being 


struck down. 


MS. MUNN: I guess the basic question still 


hasn’t changed. The question is still how 


good is good enough. Because certainly we’re 


not ever going to get absolute correlation 


between any two databases anywhere as long as 


this --


MR. GRIFFON: This is a half full and half 


empty issue. 


MS. MUNN: Yes, it is. It is. 


MR. GRIFFON: How bad is too bad. That’s 


the other side of it. And I mean, I just, 


again, I’ve looked at some of this. Some of 


this comes up in the log book review. I 


looked into some exposure IDs that come out of 


the log book analysis, and when you track them 


back, I almost found like every time I was 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

131 

finding exposure ID in the 100,000 series that 


didn’t exist in HIS-20. 


So this is very odd. It seems like 


trends like this keep popping up, and it’s not 


one or two individuals. I did a little mini-


analysis looking at how many exposure IDs, 


NIOSH provided us with a spreadsheet with 


exposure IDs for individuals so that we can 


link that to the ACCESS HIS-20 database. 


And if you compare, you know, I just 


saw this, and this is, again, no scientific 


sampling method, but I just sort of saw this 


trend of individuals I was finding in the log 


books with six-digit IDs starting one-zerozero-zero-zero. And when I looked, they just 


weren’t in HIS-20. So then I said, well, how 


many individuals are in the exposure ID Excel 


sheet versus how many are in the ACCESS 


database. And it seems like there’s about 15 


percent as many in HIS-20 as were in the 


exposure IDs. 


Now maybe there’s a good reason for 


that. Maybe those people were not in the 


plutonium areas or whatever. It certainly 


wasn’t by year as far as I can tell. But 

1 

2 

3 

4 

5 

6 

7 

8 -- 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

132 

again, it’s just this, you know, adding up 


these pieces when you have these kinds of 


discrepancies in the data it just makes me a 


little uneasy. And that’s why I’m saying at 


least one sub-test for me I think is for us, 


we need to go back to that old report that we 


kind of went past in a work group meeting and 


DR. NETON: Well, there’s two things, Mark, 


one is you’re talking about comparing the CEDR 


and the HIS-20 for comparability of film sets 


to internal intakes. 


MR. GRIFFON: Yeah. 


DR. NETON: But then I think, I know Brant 


and I had talked, and he had done an analysis 


where similar to what was requested for us to 


do at Y-12. He went back and looked at the 


environmental reports from the health physics 


monthly reports. He compared the numbers, and 


I haven’t looked at it for awhile, but I 


thought it was a pretty good comparison so at 


least the numbers that were being reported in 


the monthly reports were matching up with what 


was in HIS-20. And I think we better take a 


look at that and see --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

133 

MR. GRIFFON: Yes, and he just told me 


about, I think I didn’t get that e-mail for 


whatever reason, but --


DR. NETON: There were some discrepancies, 


but I think it would be useful to look at. 


DR. ULSH: What I found was that --


MR. GRIFFON: That would be useful to look 


at though because that’s what helped us in Y12 was looking at that summary sort of --


DR. NETON: We did that in Y-12 and it 


seemed to satisfy people a little bit. Let’s 


go down that path. 


DR. ULSH: Jim, I haven’t looked at it 


probably since the last time you looked at it 


but just going from memory, just to summarize 


what was there, it started, the progress 


reports that I had covered the timeframe 1952 


up to 1971, I believe. Again, all of this is 


approximate because I’m going from memory. 


There was one year in that period 


where I didn’t have the progress reports, so I 


didn’t do an analysis for that year. There 


was another year where I had the monthly 


progress reports for January through November 


so I, there was another year where I had the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

134 

progress reports for January through November. 


I was missing December so I made an 


extrapolation there. With those caveats I 


think what I saw was that the average 


difference between a number of bioassay points 


in CEDR versus the monthly progress reports 


was about five percent. They were within five 


percent of each other. 


MR. GRIFFON: Of CEDR versus the monthly 


progress or HIS-20? 


DR. ULSH: CEDR versus the monthly progress. 


No, CEDR versus the monthly progress reports 


because recall --


MR. GRIFFON: Because you were using CEDR, 


right, for your --


DR. ULSH: Well, yes, that’s one reason. 


But the other reason is that we know that in 


HIS-20 some individuals’ data is not in HIS-20 


because they terminated employment prior to 


’77. That issue is there. So what I saw with 


the CEDR, you know, I don’t want to make too 


much of this comparison. I mean, you can’t go 


beyond what the bounds of the data are, but 


over that time period there’s very good 


agreement, at least I think there’s very good 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

135 

agreement, within five percent on average, 


between CER and the progress reports. Now 


that’s an average over the years, but I will 


send that report out to you again and 


hopefully that can go partway towards --


MR. GRIFFON: And the entire work group I 


guess. 


Did you get the e-mail? 


DR. ULSH: I don’t remember when I sent it. 


It wasn’t recently. It was at least a couple 


of weeks or maybe more. 


MR. GRIFFON: At any rate that’s a new piece 


of information. So that’s helpful. I mean, 


any prong we can come at to answer this 


question I think is helpful. I think we’re 


down to a weight of the evidence. We’ve got 


some discrepancies, but how bad are they or 


how small are they, and can they be overcome 


by the fact that we have some assurance that 


the, you know, it won’t affect the intake 


estimates or things like that, the bottom line 


sort of thing. So if SC&A can look at both 


this report that Brant’s discussing and that 


prior report by Lockamy, the earlier report, I 


think that would be helpful. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

136 

MR. FITZGERALD: Do you recall if the 


Lockamy report had the spreadsheets or the 


background stuff associated with it or not? 


But that might be something. 


DR. ULSH: I’m not sure what you mean in 


terms of --


MR. FITZGERALD: The Lockamy report itself. 


DR. ULSH: Yeah, I know that, but what --


MR. FITZGERALD: In terms of the back, the 


supporting data. 


MR. GRIFFON: Did he have his analysis in 


there or was it just a summary of what he --


MR. FITZGERALD: I recall the analysis 


itself. 


DR. ULSH: I’ll have to go on the O drive 


and look because there’s a folder here for 


that. 


DR. LIPSZTEIN (by Telephone): Let me just 


say something? 


MR. GRIFFON: Yeah, Joyce, go ahead. 


DR. LIPSZTEIN (by Telephone): I think, 


well, first of all two things. One, we are 


going to the 95th percentile, and I think we 


favor any of the possible problems, 


uncertainties that we have (unintelligible). 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

137 

And other thing is that this is a model for 


like for example, there was (unintelligible). 


It’s just one intake rate from ’52 to ’61, and 


of course, there’s a big difference between 


one year and another year, like for example 


from the first year to the second year there 


are three times difference from the intake. 


The intake is what’s calculated in those 


years. They have a lot of difference from one 


year to the other. 


MR. GRIFFON: But Joyce, I think this 


comparison document that we’re talking about, 


I think he looked at year by year. I think 


there’s enough --


DR. LIPSZTEIN (by Telephone): This is year 


by year, but when they come to the model, it’s 


a model, so it’s just one intake for ten 


years. Then there’s another intake that was 


calculated for seven years. So --


MR. GRIFFON: But I thought the application 


was that --


DR. LIPSZTEIN (by Telephone): What I mean 


is that some uncertainties on the database 


wouldn’t make too much difference in a model 


like that, but I think it’s acceptable when we 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

138 

go to the 95th percentile. 


MR. GRIFFON: When you’re at the 95th, right. 


DR. LIPSZTEIN (by Telephone): Because, you 


know, it’s not exact anyway. You know, it’s a 


lot of estimation. Imagine just one intake 


for ten years. 


MR. GRIFFON: Yeah, I think, I know what 


you’re saying, Joyce. I think we should at 


least look at that prior piece though and look 


at the --


DR. LIPSZTEIN (by Telephone): Okay, okay. 


MR. GRIFFON: And I think this Health and 


Safety Report thing might be very helpful, 


too. Did that have internal and external or 


just --


DR. ULSH: No, just bioassay. 


MR. GRIFFON: Just bioassay, okay, just 


curious. 


MS. MUNN: But there’s such a wealth of data 


here that it’s hard to imagine in light of no 


evidence of programmatic error that we can’t 


resolve this. 


MR. GRIFFON: That’s why we’re following 


this up because we’ve got the, at least 


potential that some blanks were zeroed out in 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

139 

the database. So that’s evidence of 


programmatic problems. I’m not saying 


intentional or otherwise. I’m just saying, 


you know. 


MS. MUNN: Yeah, but if you’re constructing 


a dose then, well, that’s --


MR. GRIFFON: I’m not saying it’s 


insurmountable either. I’m not, but I think 


we’re, all I’m saying if we can be looking at 


these things in parallel, SC&A can look at 


that while NIOSH is finishing their data 


completeness response, then at the next 


meeting we’ll be ready to maybe discuss and 


the application of those coworker, you know, 


whether they’re okay and if SC&A has any input 


on how they should be applied, you know, that 


sort of thing. 


DR. MAKHIJANI: I have a question on this 


one number, the 95 percentile for all years. 


What happens if a worker worked for just one 


year? What do you do with that in terms of a 


claimant favorable number? And if he happened 


to have worked in the years where he had --


DR. NETON: He would get the intake for that 


one year, but if you’re asking what Joyce is 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

140 

alluding to which is these differences, I 


don’t know. 


DR. MAKHIJANI: Would you use the number for 


that year or would you use the same coworker 


model number that you’re using for one number 


for ten years? 


MR. GRIFFON: This is sort of an application 


question? 


DR. NETON: Mutty Sharfi might know. 


MR. SHARFI: Then you’d likely go back to 


the raw coworker bioassay data and then 


construct its own coworker intake rate based 


off the coworker bioassay data. You wouldn’t 


use those broad long-term periods. 


MR. GRIFFON: The one year that they were 


employed, right? 


MR. SHARFI: You would look at the more 


refined periods. 


MR. GRIFFON: Seems to make sense. 


MR. SHARFI: You can refine the coworker 


intake numbers to fit the specific case 


scenario. 


DR. MAKHIJANI: Oh, great, okay. 


MR. SHARFI: You’re not locked into those 


numbers. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

141 

DR. LIPSZTEIN (by Telephone): That’s not 


what’s said on OTIB-028. Actually, it states 


that but I can’t --


MR. GRIFFON: Well, wait, I think we’re 


getting into the application question. We can 


talk about this more. I don’t think right now 


is the place, Joyce. 


DR. LIPSZTEIN (by Telephone): Okay. 


MR. GRIFFON: I think the sense I had was 


that the application is you use that broader 


average and then you have sort of an if-then 


tree. And then you might go back to the 


annual data if you need to, right. 


MR. SHARFI: That’s why the tables are 


provided in the appendix of the OTIB is that 


if you need a more specific for the case you 


can. 


MR. GRIFFON: Then you go annual, right. 


MR. FITZGERALD: Say you had a number of 


questions that sort of get into how would you 


apply it because I think that’s a --


MR. GRIFFON: Application question, yeah. 


So I mean, I think we’re there on the 


actions we need on the coworker stuff and that 


may be very helpful, the latest report. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

142 

MR. FITZGERALD: And I think these are 


pretty narrowly defined, and I think we can 


again get that. 


OTHER RADIONUCLIDES - THORIUM
 

MR. GRIFFON: I think we’re on to item four, 


thorium, other radionuclides, thorium, I think 


is what we’re down to. And I know that there 


was a technical call in between meetings, and 


I apologize for not having that in my 


Blackberry and missing it. But anyway --


DR. MAKHIJANI: Do you have the minutes from 


that? 


MR. GRIFFON: Yes, the minutes were sent 


around to, I think, you got those as well, 


Wanda? 


MS. MUNN: Yes. 


MR. GRIFFON: So anyway you can summarize 


where, Arjun or Brant? I don’t know who wants 


to start. 


DR. ULSH: As Mark mentioned we did have a 


conference call about a week and a half, two 


weeks ago, something like that, on thorium 


issues. Just to bring you up to date with 


where we are, you know, we’ve been looking at 


the thorium issue for months now I think. The 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

143 

latest document that we’ve put out was 


December 27th, and after that SC&A issued some 


comments and evaluation of that report. That 


was in early January along with the others I 


think. The topic of the conference call, 


there were two main topics. 


The first was the question of 


magnesium alloy which contained up to three 


percent thorium according to the workers who 


were involved. There’s a long story involved 


with this and it pulls in another site, the 


Dow Madison site in Illinois. I was going to 


say Wisconsin, but it’s Illinois. 


And there’s an active SEC petition at 


that site, and there were some interviews 


conducted not by NIOSH but by some of the 


petitioners involved in that site with Dow 


Madison workers. And there was a question 


brought up about, well, first of all it was 


whether or not thorium was shipped from the 


Dow Madison site to Rocky Flats and/or vice 


versa. We later clarified that we were 


talking really about magnesium-thorium alloy. 


And the Dow Madison worker who talked 


about this said it was up to three percent. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

144 

And there’s still some questions I think, at 


least there were at the time of our conference 


call, about to what extent this might have 


occurred. 


We presented at the conference call, I 


think we sent out the interview notes after 


the conference call, but we talked to four or 


five, I don’t remember which, Rocky Flats 


workers, and they did not recall large uses of 


magnesium-thorium alloy at Rocky Flats. 


They did recall one specific use of 


the magnesium alloy, and it wasn’t clear 


whether it was magnesium thorium or not. And 


that was in the pennates (ph) in the conveyor 


line in Building 776, I believe, the one where 


the Mother’s Day fire occurred. That was it. 


That was the only big use of magnesium alloy 


that they were aware of. 


And I should qualify that. It’s not 


big, but we’re talking about maybe a couple of 


hundred pounds according to one worker’s 


estimate. That was really it. I mean, we 


didn’t see, the workers didn’t recall any 


program, large scale program to use magnesium 


alloy at Rocky. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

145 

Let me see, I’m trying to think of all 


the other developments that have occurred. We 


have since learned, we’ve received some 


documentation that tells us the source of the 


thorium that came into Dow Madison. It was 


from Canada, and that was with pellets. 


Ingots came from England I think is what the 


workers said, and we see nothing to dispute 


that. So it doesn’t look like the source of 


the thorium going into Dow Madison was Rocky 


Flats. 


But that doesn’t speak to the question 


of whether or not the destination was Rocky 


Flats. Again, the four workers that we’ve 


talked to, and these are folks who were 


involved with the Operations Board at Rocky 


Flats. I might have the names of those 


committees wrong, and I don’t know, maybe you 


can correct me on that. 


But the folks that were in charge of 


all shipments of radioactive materials that 


came into the site and then also the 


Operations Committee, they didn’t have any 


recollection of large scale use of magnesium-


thorium alloy at Rocky. And in terms of the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

146 

pennates that they did know about, they did 


state specifically that those were prepared by 


an outside vendor and delivered to Rocky 


Flats. 


So that was one issue. I think that’s 


pretty much where we left it. We were going 


to get the notes to SC&A, and we’ve done that. 


And that’s pretty much where we left that 


issue on the conference call. 


Now, Arjun, do you want to talk about 


that before I move on to the other topic? 


DR. MAKHIJANI: Yeah, I have the same 


document that you have, I think, regarding the 


thorium pellet supply from Canada. I just 


wanted to note that in the amount of thorium 


we had at Dow Madison for this alloy program 


was quite large, 80 tons up to 1960. So that 


would mean we got about 2,400 tons of alloy, 


three percent thorium. So they were 


fabricating making the alloy on a very large 


scale at Dow Madison. Of course, we don’t 


know where it went, but as I understand, I was 


talking to Tony at lunch about whether they 


did fabrication of things, you know, like 


trays and other parts at Rocky Flats. And I 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

147 

do understand that ad hoc or custom parts were 


fabricated at Rocky Flats. 


Correct me if I’m wrong, Tony, or 


misinterpreting our conversation. 


MR. DEMAIORI: No, absolutely, we did a lot 


of fabrications at Rocky Flats. We built our 


own part carts with the lead shelvings. We 


used stainless. We used all kinds of 


different materials. We had our own 


fabrication baths for the trucks to ship the 


nuclear components themselves. I mean, we 


armed them. We put the bulletproof glass in 


them. We did all that. We had the hobby shop 


where they did some secret fabrications in 


there. 


This issue of thorium, as a rad tech I 


can tell you that we had thorium in almost 


every toolbox on the plant site, that’s in the 


way of welding rods. So welders commonly use 


thorium rods for the different welds that they 


were making. You know, pretty much we did our 


own thing, but yeah, we did a lot of 


fabrication out at Rocky Flats. 


Now when I was there, and that was 


late ‘70s, 1979 and on, it was mostly 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

148 

stainless steel because it was very acid 


resistant. But we definitely built our own 


carts and did that sort of thing. We built a 


lot of things that they used at Rocky Flats. 


And so, you know, I don’t know on this 


magnesium-thorium alloy, but I can find out. 


I know a lot of machinists that would do the 


fabrication, and you know, I can definitely 


check into that. 


The people who did the shipping and 


receiving, as far as shipping and receiving 


went, we got a lot of things into Rocky Flats 


that we didn’t expect to get. Talk about 


americium (unintelligible) all the salts from 


the United Kingdom were extremely hot. So 


nothing is perfect, but I can definitely tell 


you that we did a lot of fabrication out at 


Rocky Flats. That’s all of our research and 


development, 779, on the hot side, and then we 


would take 887 on the cold side. They did all 


the beryllium operations, all the R&D for 


that. We fabricated everything. 


MR. ELLIOTT: But the numbers that Arjun 


quoted on thorium production at Dow Madison, 


we know, I think it’s a common understanding 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

149 

here that Dow Madison had other work, large 


thorium commercial component that they 


performed. And much of that was dedicated to 


Department of Defense effort. So I’m only 


concerned here about what we can say about the 


production for the AEC portion and where that 


went. I don’t want to get the two confused. 


DR. MAKHIJANI: No, I don’t want to get them 


confused, and it is correct that the documents 


that you sent to Senator Salazar’s office, 


which I have here, they do indicate that 


magnesium-thorium alloy was I guess in large 


measure, in some measure at least, being 


considered for like aircraft parts and things 


like that. And the other document we have 


about thorium-magnesium alloy, the NUREG-1414 


also said the same thing, that that was --


1770, sorry -- so I would agree with that. 


It’s just the extent, my only question, reason 


for raising that is the extent of use at Rocky 


Flats is, well, based on the recollection of 


talking to a few people. And there’s not a 


definitive trail of what happened when it 


started, when it stopped, how much, and most 


importantly, whether it was, there was any 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

150 

fabrication work there. We understand from 


these claimants that there was no, they were 


not fabricated on site. 


DR. NETON: We don’t even know that material 


was shipped to Rocky Flats from Dow Madison. 


That’s not a foregone conclusion. I mean, 


that’s speculation. 


MR. ELLIOTT: We have no indication in the 


documentation that we have obtained from DOE 


thus far there was any transfer of thorium-


magnesium alloy from Dow Madison and Rocky 


Flats. We haven’t seen that. 


DR. NETON: I’m just wondering if we’re 


chasing down something that might not have 


happened. I mean, I think we just need to 


establish the material was actually shipped 


there before we start --


MR. ELLIOTT: We don’t doubt that there was 


fabrication at Rocky Flats, but I don’t 


believe we have any indication that says the 


processes at Rocky Flats required fabrication 


of thorium-based metal parts or et cetera. So 


we’re still interested in understanding how 


thorium may have been introduced in the site. 


But to date we have no indication in the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

151 

documentation we have that there’s a large 


thorium component here. 


DR. NETON: Thorium alloy, component 


magnesium-thorium alloy. 


DR. MAKHIJANI: Yeah, there obviously was 


some thorium alloy at, in the form of welding 


rods now --


MR. DEMAIORI: Oh, absolutely. 


DR. MAKHIJANI: -- in the form of magnesium-


thorium alloy. There was some presence at 


least according to interviews that you’ve 


done. 


DR. ULSH: There was magnesium alloy 


present. We don’t know if it was magnesium 


thorium. 


DR. NETON: And that was manufactured off 


site. 


DR. MAKHIJANI: I didn’t understand that 


from our conference call. I thought that your 


reference to magnesium alloy was magnesium-


thorium alloy, from our conference call. 


DR. ULSH: Here’s the minutes. All* also 


stated that magnesium alloy was used in the 


Building 776 line. The pennates were made of 


magnesium alloy. Now we don’t know whether 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

152 

that was magnesium-thorium alloy. It was 


magnesium alloy. We also know from the chemrisk report, task one, that went through an 


extensive list of like 300 pages, I think, of 


all the chemicals and all of the materials on 


site. 


They talked about magnesium in terms 


of magnesium salts and small quantity of 


magnesium alloy. Now it’s not clear whether 


it’s magnesium thorium, just magnesium alloy, 


0.5 kilograms in the chem-risk report. And 


that was at that time. So this was not 


identified in the chem-risk report as a 


material of concern. 


And then we have the testimony from 


the four workers, which this actually came up 


I think at the last working group meeting. 


And what we committed to do or what we were 


asked to do was to go, Mel suggested that he 


would go talk to these folks, and that’s what 


he did. He told us that they had no 


recollection of, certainly not extensive use 


of magnesium-thorium alloy or magnesium alloy 


at all. 


DR. MAKHIJANI: I’m concerned in reviewing 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

153 

the material unless the working group desires 


otherwise, I mean, we’ve said what needs to be 


said in terms of raising the questions about 


the source term. And some new questions have 


been introduced and a new source term, you 


know, there were two items in the December 


report. 


And subsequent to that the 80 ton 


ingots and the magnesium-thorium alloy, and we 


know the 80 ton, 80 kilogram ingots, sorry 


about that. So I don’t know where, I mean 


it’s the pleasure of the working group whether 


there’s anything further to be done. 


MR. GRIFFON: I think we’ve left it with two 


questions kind of. One was on the source term 


side, and the other was this question of 


empirical models. Have empirical models be 


developed. So on the source term side, I 


don’t know, the question on the ingots raised 


my, I mean I guess what NIOSH concluded was 


that the latest report that gives more 


information on those ingots, the amounts were 


consistent with the earlier mass balance 


review. Is that fair? 


DR. ULSH: Yes. 

1 

2 

3 

4 

5 

6 

7 

8 

9 -- 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

154 

MR. GRIFFON: I’m trying to remember myself. 


And then on the other side the 


assembly, the mock-up assembly, sort of 


operation, it seemed to be that those would 


have been smaller uses certainly, and probably 


less exposure generating tasks. I’m not sure. 


DR. ULSH: We’re still talking about that. 


I don’t want to put words in SC&A’s mouth, but 


MR. GRIFFON: Well, just on the source side 


though, smaller amounts I guess. 


DR. ULSH: Yes. As I mentioned in this 


topic-specific conference call, there were two 


major topics. One was magnesium-thorium 


alloy, and number two was the concerns that 


SC&A’s expressed about our empirical approach 


to estimating possible bounding thorium 


intakes. That was topic number two. Before 


we move on to topic number two, I guess I’d 


like to get your feel on like what Arjun said, 


what comes next with the magnesium alloy? Are 


you okay with where we are? Do you want to 


see some more specific actions? Or what’s the 


pleasure of the working group I guess. 


MS. MUNN: Certainly, this working group 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

155 

member thinks we’ve beaten the magnesium alloy 


thing to death, and I see, I don’t know where 


we could go from there. It appears to me that 


we’ve researched whether we did, in fact, have 


magnesium alloys, and we’ve identified four 


individuals who had total plant oversight at 


one time or other and were part of the 


Operations Board, all of whom would have known 


of any extensive use of magnesium alloys. 


They all had the same general response. 


Unless there is some significant issue with 


respect to magnesium-thorium alloy 


specifically, I can’t see that we can take 


magnesium much further. It seems clear to me 


that it’s not a major issue. 


MR. GRIFFON: Magnesium-thorium alloy would 


be the question of concern. But, yeah, I 


can’t, you know, short of additional 


information, which I don’t see on the horizon, 


I don’t think there’s much we can do with 


that. And I think all the evidence, I mean, 


from what I can see so far and this is just my 


personal opinion right now from what I’ve 


seen, is that it doesn’t, you know, it looks 


like if any was shipped we can’t find any 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 -- 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

156 

evidence that there was any significant 


fabrication or with that material at Rocky. 


So from an exposure standpoint I don’t 


think it’s worth chasing, so to speak, unless 


other clear evidence is brought before us. 


But I don’t think there’s any further action. 


Now, Arjun, what’s your sense of that? 


It’s sort of up to the work group. 


DR. MAKHIJANI: Yes, it’s entirely up to 


you. We raised the question. NIOSH followed 


up and did the expert interviews, and I think 


MR. GRIFFON: So that’s my feeling on the 


magnesium-thorium alloy is that I don’t know 


that we’re going to, you know, we’ve got some 


statements. We’ve tried to check them the 


best you could. You’ve come back and we don’t 


have any indication of, certainly no 


indication of fabrication at the site and very 


little indication of any use, and limited if 


any use, you know. So I think we’ve chased 


that about as far as we can at this point. 


MS. MUNN: Pretty well documented. 


MR. GRIFFON: The only other thing is maybe 


if Tony does get back to us from talking with 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

157 

some of the former workers that have knowledge 


of this then that’s new information before us. 


So I think we have to address that. But short 


of new information I think we’ve chased it as 


far as we can at this point. 


Now were you going to, I mean, on the 


other source term side before we get into the 


techniques for bounding, I guess on the other 


source term side I was looking at some of the 


Health and Safety reports as were probably 


some of the ones you were looking at for the 


database completeness question. In some of 


those reports they talked about developing a 


thorium urinalysis program. 


And they did talk about some limited 


air sampling data. You might have seen some 


of these same reports. So it made me wonder 


if any of these reports, because you’ve gone 


through certainly more than I have of these, 


if any of these reports shed further light on 


a more extensive operation with the ingots, 


with the rolling, with that kind of thorium 


work. 


DR. ULSH: They do shed some light on that, 


Mark. It was in the, yeah, I think it was 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

158 

those same progress reports that you mentioned 


that you do see occasional mention in 1960 


that they were attempting to develop methods 


for thorium urinalysis. And that was in 


advance of that ingot project in 1960 that was 


covered in that report. 


In fact, in our December 27th report we 


talked about all of the thorium bioassays. It 


was easy because there weren’t many. They 


were developing those things for the ingot 


operation. There were a couple of individuals 


who I think one of them wound up, they 


concluded that he had worked in a thorium 


refinery prior to Rocky Flats, and that’s why 


they saw, you know, I think they saw some 


thorium in his urine. 


MR. GRIFFON: Yeah, I remember that exact 


distinction, yeah. 


DR. ULSH: So that was some of the 


urinalysis results, maybe two, three, I don’t 


know. There was another individual that came 


up with a funny peak in his, or an unexpected 


peak in his whole body count. Bob Bistline 


wrote a report on that one, and it turned out 


that it was not related to thorium. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

159 

And then there were a few confirmatory 


bioassays taken related to the ingot, thorium 


ingot project. And that was pretty much it. 


That’s all we’ve seen with regard to thorium 


bioassay. So I don’t think that those would 


speak to a wider thorium use program than what 


we’ve already identified. 


MR. GRIFFON: And those reports where they 


discuss the urinalysis program, those 


timeframes are consistent with what you saw --


DR. ULSH: Yes. 


MR. GRIFFON: -- as the thorium project in 


other documentation. 


DR. ULSH: The thorium project, the main 


document that we had describing the ingot 


project was authored by a guy named Callabra 


(ph). He wrote an extensive report on that 


operation, and it gave exact times of when it 


happened. 


And we also found notations on this 


project in the Kittinger logs of the time. So 


we know when that ingot project happened. It 


happened on eight working days spread out over 


the latter part of 1960s. And this 


development work that you’re talking about 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

160 

where they talk about the progress reports, 


that was earlier in 1960. They were trying to 


develop that in advance of that project. 


MR. GRIFFON: And where did this ingot 


processing happen? What building was that in? 


Do you recall? 


DR. ULSH: Primarily in Building 881, but I 


think they did some acid, processes that 


involved acid. I think etching maybe in 331 


maybe, one of the 300 buildings, 331, 334. 


That was also laid out in the Callabra report, 


but primarily in Building 881. 


And we also saw, that was consistent 


with what we saw in the chem-risk test three 


report. It talked about the uses of thorium 


and where it occurred. And that was 


consistent with what was in that report as 


well. 


MR. GRIFFON: And then the assembly, the 


mock-up assemblies? 


DR. ULSH: Okay, now, that’s a second 


category of operations. So in terms of the 


quantity of thorium that was used at Rocky, 


that was primarily in that ingot operation. 


They had three ingots of the dimensions, they 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

161 

were 12 inches by 12 inches by three inches. 


So we’re talking, physically anyway, they were 


fairly small ingots, and there were three of 


them. That was about 240 kilograms, and 


that’s a majority of the thorium inventory 


that we saw in ledgers at Rocky Flats. 


Now in terms of the number of 


operations, there were occasions when Rocky 


Flats would receive these finished parts from 


Oak Ridge to use in their models. 


MR. GRIFFON: That was (unintelligible). 


DR. ULSH: So that’s a separate operation 


there. 


And then you had smaller uses of --


MR. GRIFFON: We don’t know the extent --


I’m sorry to interrupt -- we don’t know the 


extent of, I mean, that one memo suggested 


that those uses were sort of below what would 


have been recorded on the mass balance. 


Although Mel suggested, or Bryce, I forget who 


had suggested, that if the building exceeded a 


certain amount, it would have been rolled into 


that mass balance summary. Is that accurate? 


Am I off-base on that? 


DR. ULSH: Well, you might be talking about 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

162 

yet another, there were, I think, four uses of 


thorium that we’ve identified. One was ingot. 


Two was the use in weapons mock-ups. Three 


was the use in laboratory standards. 


MR. GRIFFON: Now I think I’m talking about 


two, the mock-ups. 


DR. ULSH: The mock-ups. 


MR. GRIFFON: Where they said that they 


would have been, I think the one paragraph in 


that memo it was the history of thorium use, I 


think, at Rocky Flats, in that memo. 


DR. ULSH: Okay, the Bob Bistline report. 


MR. GRIFFON: Yeah. And it indicated in 


that one paragraph that currently I think it 


said seven kilograms onsite, but it might have 


been a 0.7. It was a blurry copy that I was 

looking at. 

DR. ULSH: Yeah, I think that was 

cumulative, totally. 


MR. GRIFFON: But anyway, it suggested that 


earlier period would have had more but still 


each individual use was below what would be 


reported on these forms. I don’t recall the 


exact language. I’d have to go back to the 


reference, but --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

163 

DR. ULSH: I don’t either. I don’t have 


that in front of me. 


MR. GRIFFON: My question was how extensive 


was that operation. Are we talking about a 


lot of small uses that when you aggregate 


them, and how long did it go on sort of that ­

-


DR. ULSH: Well, in order to answer that 


definitively, in other words, we could get 


some indirect evidence from the MDA ledgers in 


terms of we could look at when the inventory 


changed and get some indication of when they 


might have received a part from Oak Ridge, and 


when they might have sent them back. Then we 


can, if it’s the working group’s pleasure, 


then we can do that. 


In fact that’s one of the concerns I 


think that Arjun’s report talked about was 


that we have reported inventory numbers and 


not through-put numbers. Now what -- I did 


not actually do this. Mel and Bryce did and 


Mark Rolfes. What they did was they reported 


the highest inventory for the year. In order 


to get, and what Mark told me, he looked at 


these ledgers, was that there were very few 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

164 

times when the inventory actually changed. 


But we can get those numbers if --


MR. GRIFFON: I don’t know that we 


necessarily need them. I thought maybe from 


your interviews you can give us the scope of ­

-


DR. ULSH: It was not, all the interviews 


that we have conducted have indicated, number 


one, that this was a very unusual occurrence. 


I don’t even want to hazard a number, but it 


wasn’t like an everyday occurrence. It was 


special order work, and it was not extensive. 


Now we have talked to, regarding these 


uses in weapons mock-ups, we’ve talked to four 


R&D machinists just recently, and we’re about 


to send out these interview notes to everyone 


because SC&A has expressed continuing concerns 


about how we’re going to bound the dose of 


this particular use of thorium. So we went 


back and talked to these machinists. 


And I think we need to be very clear 


here that we don’t confuse the machining 


operations that occurred when the only 


indication that we have that these parts from 


Rocky Flats were machined was one interview 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

165 

that we conducted with a site expert, and he 


said the parts might have been lightly 


trimmed. 


MR. GRIFFON: Parts from Rocky Flats or from 


Oak Ridge? 


DR. ULSH: From Y-12. 


MR. GRIFFON: From Y-12, you said from Rocky 


Flats. 


DR. ULSH: Oh, I’m sorry. 


MR. GRIFFON: From Y-12, I’m just trying to 


stick with it here. 


DR. ULSH: Yes, they received the parts at 


Rocky Flats from Y-12. And that individual 


was not a machinist. He was very 


knowledgeable at the site. He was one of the 


people that we talked to about maybe using 


thorium alloys. We had a general picture of 


where things were at the site. 


But we have talked to four R&D 


machinists. These guys worked in Building 991 


where this operation would have occurred, and 


none of them could recall ever actually 


machining these parts. I mean, the problem is 


I can’t say to you with 100 percent certainty, 


well, they never ground off a high spot. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

166 

I can’t say that because I don’t know 


that, but that’s the only indication that we 


have that they did anything other than take 


them out of the box and bring them 


(unintelligible) so far. And I think it’s 


fair to say that NIOSH and SC&A have not yet 


reached closure on how to bound doses for that 


particular operation. Fair enough? 


DR. MAKHIJANI: Yes. 


MR. PRESLEY: Are those interviews for those 


machinists going to be seen? 


DR. ULSH: I hadn’t planned on it, Bob. I 


can show them to you. I’ve got a hard copy 


here. They don’t go into detail, I mean, it 


was pretty much, it was very focused. And it 


asked do you ever recall machining these 


parts, something like that, one question. 


MR. PRESLEY: Okay. 


DR. ULSH: I’ll talk to you afterwards about 


that before we send it out. If there’s any 


concern at all, we don’t want to cross any 


lines. 


MR. DEMAIORI: What year was that --


DR. ULSH: The ingot operation or the parts? 


MR. DEMAIORI: Parts for the machining. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

167 

DR. ULSH: I can’t really tell you, Tony. I 


don’t know exactly without going back to get a 


more detailed look at the MDA ledgers. It was 


early on in Rocky Flats history, but I don’t 


know the exact years. 


MR. PRESLEY: Late ‘60s. 

MR. GRIFFON: Nineteen-sixties? 

MR. PRESLEY: Mid-to-late ‘60s. 

MR. DEMAIORI: Because most of the machining 


R&D was 887. So I was just wondering. They 


may have not built 887, you know, in the late 


‘60s. But when I was there, the bulk of the 


R&D machining was 887. 


DR. ULSH: Yeah, this is certainly in the 


earlier years, in the ‘60s, maybe in the ‘50s. 


I don’t know exactly when. In order to answer 


that question we would need to go back and get 


a look at the, closer look at the MDA ledgers. 


There were two other thorium 


activities, thorium strikes, and what that 


involved was some special order work that 


Rocky Flats conducted with uranium-233. And 


that uranium-233 had trace contaminants in the 


beginning 50 ppm and later on down to seven 


ppm of U-232 which daughter products of which 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

168 

are thorium-228. 


And so in order to work with this 


uranium-233, they had to remove those thorium 


daughters. And this occurred on -- well, I’m 


looking at the chem-risk report right now. 


Twice during the ’64 to ’69 time period, but 


there were some other ones later. Again, not 


a common occurrence but a handful of 


occurrences. 


And unless you look at this you may 


not know, but there is a very great external 


exposure hazard with this kind of an 


operation. We have seen notations about this 


in the Kittinger logs and describes when it 


occurred, and that they did cover it with 


health physics support. It was a small 


operation in terms of the number of people 


involved. 


MR. GRIFFON: Do you have a sense of the 


people, how --


DR. ULSH: Pardon me? 


MR. GRIFFON: How many people? 


DR. ULSH: A dozen at most and that’s 


probably an overestimate. 


But they removed the thorium 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

169 

daughters, the thorium-228, and the daughters 


from the uranium-233 before they processed the 


U-233. Now for those operations we have 


proposed a NUREG-1400 approach. But again, 


SC&A’s expressed some concern about that 


approach, and we are currently considering 


their concerns about that. 


And finally, we have these various 


miscellaneous, very small uses of thorium like 


in laboratory standards, that kind of thing. 


I think that covers the four categories, 


right, Arjun? 


DR. MAKHIJANI: Yes. 


MR. FITZGERALD: The only clarification I 


would add, I think the way we had left it 


because the concern was the semi-empirical 


approach I think from our standpoint didn’t 


demonstrate conservatism necessarily, and I 


think the response was to consider a, perhaps 


a bounding analysis for the three activities 


other than the ingots that were, you just 


talked about. I think that’s the way we left 


it there at the end, and I think there was 


some agreement that you would look at that. 


Is that still the case? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

170 

DR. ULSH: That is the case, Joe. That’s 


the way I recall it, too. But I think it was 


not SC&A’s position that they couldn’t be 


bound. It’s just that you were not yet 


convinced with any bounding analysis that we 


had yet presented. 


MR. FITZGERALD: Yeah, I think that was it. 


MR. GRIFFON: So that’s an outstanding 


action. 


DR. ULSH: That is an outstanding action. 


MR. GRIFFON: And what about, you said other 


than the ingot operation? 


MR. FITZGERALD: Yeah, I think we were 


focusing, I think the conclusion of the review 


that we presented was that we were okay with 


the ingot operation in terms of the monitoring 


that was done, but the other three where 


NUREG-1400 would be essential, those were the 


three that --


MR. GRIFFON: What is the proposal? You 


probably told me this before, but what’s the 


method for the ingots for dose reconstruction? 


If they were involved in that operation, how 


do you reconstruct their dose? You have some 


urinalysis --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 -- 

21 

22 

23 

24 

25 

171 

DR. ULSH: We did have, okay, there was some 


urinalysis, more confirmatory-type urinalysis 


to show that intakes didn’t occur. There was, 


basically, our approach was to show that there 


was no significant intake potential for that 


job. 


MR. GRIFFON: Well, that’s what I wanted to, 


the Health and Safety reports that we’re both 


looking at apparently, what I read is they do 


have references to air sampling. And it 


wasn’t clear, obviously, we run across this 


again, it wasn’t clear. I think one was over 


-- well, I don’t want to quote numbers, but it 


was high, but it said an operational sample so 


it’s not clear if it was in the rolling area 


or it wasn’t probably in a breathing zone. 


Then they gave an average of for people in the 


area I think it said, a reported number said 


20 or 30 percent of the mpl on average for the 


DR. ULSH: If we’re thinking of the same air 


sample, and I think we are, they did have the 


location listed on the air sampling card where 


the air samples were taken. One was taken 


like three feet from the ingot. Another was 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

172 

taken by --


MR. GRIFFON: Okay, I didn’t see the air 


sampling cards themselves, so maybe I --


DR. ULSH: Well, our report considered that 


and we had the detailed analysis of the job in 


terms of it was almost an hour-by-hour blow of 


the whole project. So we calculated, well, we 


felt at least, the maximum credible intakes. 


I don’t know. Arjun? 


DR. MAKHIJANI: Well, we didn’t evaluate the 


question of whether there were maximum 


credible intakes or not. We looked at the 


documents and saw that there were air 


monitoring data, and there were some high 


results, did not evaluate whether they were 


breathing, you know, they were area samples if 


I remember correctly. 


We haven’t looked at whether the model 


provides a conservative dose estimate, we just 


did note that there are air monitoring data 


and some bioassay sample data of which, and 


the bioassay sample data probably used to 


bound the dose with a minimum --


DR. NETON: That’s pretty high because --


DR. MAKHIJANI: Just from the point of view 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

173 

of an SEC issue, and I just want to say what 


we did in saying the dose reconstruction is 


feasible, but I think we know that that we 


haven’t actually examined the details of --


I know that there was a calculation in 


your December 27th report, but we haven’t 


critically evaluated that calculation to sign 


off that we would agree that that’s the 


appropriate method to use because there are 


bioassay sample data that I think would be 


used to bound the dose. And I think Jim Neton 


is agreeing with that. 


DR. NETON: Certainly, yeah. 


DR. MAKHIJANI: Now whether the issue of 


what should be done, and what would be 


appropriate would be a separate task. And 


certainly we could do that, but we haven’t 


done it. 


MR. GRIFFON: I guess we get to the question 


of do we have sufficient data that, is it 


plausible, the bounding dose. And I think we 


kind of stopped there, but we do have to at 


least make that determination. 


DR. MAKHIJANI: Well, I think with the 


bioassay data being all below the minimum 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

174 

detectable limit, you could, in principle, use 


the minimum detectable limit for bioassay 


dose. I don’t know, Joyce is not on the line 


so maybe --


MR. GRIFFON: And you have a lot of air 


sampling. I mean, I’ve got to admit --


DR. ULSH: Not a lot. 


MR. GRIFFON: -- not a lot. I shouldn’t say 


a lot, but you have some Health and Safety 


reports indicating air sampling. 


MS. MUNN: But there wasn’t a lot of 


activity going on. There wouldn’t be any 


reason for a lot of --


DR. MAKHIJANI: Well, they did have an 


incident. Now in the third rolling they had a 


failure and the high, if I recall correctly 


now, I did a quick look at these documents 


some time back. If I recall correctly, some 


of the high air concentrations were associated 


with that incident. And so you’d have to, in 


order to do an assessment, you’d actually have 


to identify those air samples, where the 


workers were and what you would do -- now 


they’re area air samples so we will get into 


the question of how the area air samples are 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

175 

to be related to what the workers were 


actually breathing, which is an argument that 


we’ve had in other contexts. But it was only 


one out of three if I recall in the other two 


cases the air concentrations were considerably 


lower. 


DR. ULSH: They were canned. If you look at 


the details of this operation, they took these 


thorium ingots, and they were trying to form 


them into shapes. And in order to do the 


operations on these ingots, they canned them. 


Now Arjun is correct that on that third ingot, 


there was a can failure. They started to see 


fractures in the joints of the can so they 


stopped. They’re done. 


And then they had to remove that ingot 


from the can, and that’s where you saw the air 


sampling, when they were taking the ingot out 


of the can. And Arjun’s right. I mean you’re 


both right. They did see detectable activity 


in those. They did. 


DR. MAKHIJANI: Well, there was detectable 


activity in the air samples, in earlier air 


samples as well, wasn’t there? 


DR. ULSH: There were smaller air --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

176 

DR. MAKHIJANI: I’ll have to go back --


MR. GRIFFON: I mean, detectable activity, I 


mean, I’m looking at, and I haven’t seen that. 


I know I probably haven’t read through all 


your details because you said you did a blow-


by-blow. 


DR. ULSH: Yes. 


MR. GRIFFON: I probably skimmed through 


that. I haven’t looked at it thoroughly. But 


the one Health and Safety report says while 


rolling coated thorium, they got a reading of 


1332 percent of the mpl. Now I don’t know if 


that sample was 1332 percent. So that’s a 


high air sample. They go on to say routine 


samples, and I’m not sure how they define 


routine samples, but I would think maybe 


something that they would assume the workers ­

-


DR. ULSH: Are you sure it was 1332, Mark? 


I thought it was 132. 


MR. GRIFFON: Well, I have pretty shaky 


writing, but I thought it was 1332. Anyway, 


routinely, to on to say routine, the average 


samples were two percent of the mpl and the 


highest was like 10.1 percent. So obviously, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

177 

that might be something more related to 


personnel exposures. I don’t know. But it 


certainly raises a question in my mind of was 


this data being considered in any way to 


establish your bound. It sounds like you’re 


saying that they had minimal overall potential 


for doses, right, in this operation. 


DR. ULSH: Well, maybe I should just stop 


and say that I think we are in agreement that 


dose could be bound. In terms of how high 


that might be, that might be more of what John 


would call a tractable issue that we could 


delve into. But I mean, I think with the 


bioassay samples and the air samples that you 


have, you can come up with a methodology to 


bound that should you ever come up with a 


claimant that was involved. Now we also have 


the names of the people that were involved in 


this operation. That was listed in the log 


books. 


MR. GRIFFON: Okay, so you have that much 


detail, yeah. 


DR. NETON: How many bioassay samples were 


there? 


MS. MUNN: You had 18 or something like 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

178 

that? 


DR. ULSH: Something like that. 


DR. NETON: Large number for a small 


operation like that. 


DR. ULSH: I think the way it was, Jim, was 


in the progress reports I found indications of 


like maybe 18-ish bioassay samples. And I 


did, and then that one log book that we looked 


at had a couple of them in there, so on the 


order of ten to 20. 


DR. NETON: It’s a reasonable number, not 


one or two. 


DR. MAKHIJANI: Were there -- sorry. 


MS. MUNN: No, go ahead. 


DR. MAKHIJANI: Were there bioassay samples 


after the incident? Do you remember? 


MR. MEYER: Eight individuals involved in 


the operation, urinalysis was requested, four 


individuals identified by name in the Health 


Physics log book were involved in that 


specific operation and no detectable urine 


activity was observed and maximum intakes 


using air activity data was not of 


consequence. 


DR. MAKHIJANI: I mean, that’s why when I 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

179 

looked at, Brant, actually I’m looking at my 


e-mail, and Brant actually had e-mailed all 


the three references, the Kittinger logs and 


the Callabra report. And I’m looking at them, 


and that’s probably why we signed off on this. 


I’m trying to reconstruct what we did. 


And so I think if you take the 


bioassay, my bottom line on this as an SEC 


issue would be that if you take the bioassay 


data, and like Joyce could comment on it if 


she has a comment, that if you take a bounding 


dose approach, and you have bioassay data, 


quite a number of samples for a small number 


of workers including after the incident, then 


you should be able to bound the dose. And so 


it then becomes a question of what’s 


reasonable if you have a claimant rather than 


whether it’s an SEC issue. It doesn’t seem to 


me to be an SEC issue. 


MS. MUNN: It doesn’t seem to be a major 


issue at all if you’re reading the report as I 


read it. It’s very straightforward. The 


fabrication of the thorium metal parts from 


three 80 kilogram ingots, it gives you eight 


hours of cold rolling on June 3rd . It gives 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

180 

you the dates, 4.62 dpm per liter square, 


approximately 30 hours of other. I mean, it’s 


very clear in the final statement here you’re 


using data from both the general report and 


the specific data from the one can opening. 


Excellent agreement is demonstrated as one 


Becquerel from the single can/uncanning task 


and three Becquerels intake from 30 hours of 


work with all three of the ingots. The 


calculated doses using different software 


programs also shows consistency of resultant 


doses less than 100 millirem to any organ. If 


that’s --


MR. GRIFFON: So you’ve been using the MDAs 


of the time. The intakes were that small? 


DR. MAKHIJANI: Well, no, --


MR. GRIFFON: The calculated intakes were 


that small? That surprises me a lot. 


DR. MAKHIJANI: This is how you would have 


done the calculation back then. I think that 


the reason for going on about thorium is if 


you read the documents back then they weren’t 


that concerned about thorium as a radioactive 


material in the ‘50s. 


MS. MUNN: We know that. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

181 

DR. MAKHIJANI: And so we understand that 


for how they viewed things then, but how we 


view things today obviously is quite 


different. And so that’s the reason for 


raising this as an issue is if the dose 


reconstruction is done with today’s science, 


then we have to take the approach of today’s 


science. And then you wouldn’t calculate a 


hundred millirem dose with today’s science. 


MS. MUNN: But the real issue is do you have 


data that was taken at the time that can be 


used in today’s world. And if I’m reading 


this correctly, we have adequate data, we have 


specific data from then. 


DR. MAKHIJANI: Oh yes, Ms. Munn, that’s 


exactly why I said that especially the air 


samples are relatively few and they would 


raise questions about whether you could 


adequately bound the dose. And we would be in 


the arena of how many air samples, and where 


was the person versus where was the sample, 


and how long the sample was. 


But because there are bioassay data, I 


think it’s not a question of whether the dose 


can be bounded. Now how you would calculate 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

182 

the dose I think --


MS. MUNN: Is something else. 


DR. MAKHIJANI: -- and whether their 


approach we would sign off on is a different 


issue. I mean, we can address that if it’s 


your pleasure that we should do it, but my own 


feeling is that in this context this is not --


MR. GRIFFON: No, no, I was actually re-


familiarizing. I didn’t remember how many 


urinalysis samples and all that. The other 


question with these kind of situations always 


for me is if you know the individuals 


involved, you have identifiers and everything. 


And that sort of answers another 


question that I have is are you going to apply 


this to anybody who ever went in the building? 


Well, probably not if you know it was only 


limited to ten or 12 or whatever number of 


people you have specific names. You don’t 


have to broadly apply it. So I think that 


answers another question I had in my mind. 


But let me just, I just want to break 


from our agenda for a second. Tony has to 


leave, but I want to offer him the floor if 


you had anything to say that the work group 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

183 

hasn’t seen you in a few meetings. 


MR. DEMAIORI: And I’d like to apologize for 


my early departure. I’m actually here on a 


job for CH (inaudible) Hill, and I wasn’t 


notified of this till after I’d scheduled my 


flight. In fact, I haven’t been getting 


notified for about six months of some of the 


working group meetings. So that was a problem 


that’s been corrected. 


However, I’d like to thank everybody 


for the hard work that you’re doing on behalf 


of all the people that worked at Rocky Flats. 


I know they really appreciate it. I know it’s 


a thankless job, and I know that everybody 


here has worked very, very hard. 


I would like to remind everybody that 


there’s two different ways that this world 


actually works. There’s the procedure that 


tells you this is how you do what when. And 


then there’s what actually goes on in the 


workplace. And sometimes they’re not 


necessarily verbatim the same. 


To give you an example I’m a rad tech, 


and I don’t think we ever passed a nod 


(inaudible) personnel. So I think we always 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

184 

failed in turbo frisking, I think is the term. 


Supposedly you frisk at one-to-two inches a 


second. On a person it’s about two minutes a 


person. Historically, we have two people on 


the step-off pad. We’re moving three to five 


hundred people in a 45 minute period. So 


statistically that’s impossible. 


Not that we didn’t try to do our jobs 


and do them very well, you know, but sometimes 


production methods, not the ideal conditions. 


So people modify and adapt and I would just 


hope that everybody would take that into 


consideration when they do go over this 


material. And that applies to all aspects. I 


don’t care if it’s machining or operations or 


dose reconstruction. 


So I just would hope that everybody 


would take that into their final 


consideration. And once again thank you very 


much. We really appreciate it. And I know 


that unless people get exactly what they want 


you probably won’t be thanked. However, you 


have to know that your hard work is definitely 


appreciated at the end of the day so thank you 


very much. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

185 

MR. GRIFFON: Thanks, Tony. We’ll make 


sure, we’ll also make sure you get all these 


pieces of the reports e-mailed to you and keep 


you in the loop better. 


MR. DEMAIORI: Yeah, I’d appreciate it. 


MR. GRIFFON: I apologize for the 


miscommunication. 


MR. DEMAIORI: You know, I guess they 


changed e-mail systems and somehow we didn’t 


get on it. However, we’re there, so it’s been 


corrected. 


MR. GRIFFON: Okay, thank you. 


Let’s take a quick break then. I 


think people want a comfort break, and it’s a 


good time. Let’s keep it at ten minutes 


though because I do want to get out of here by 


5:00. 	I’m still --


(Whereupon, a break was taken at 3:00 p.m. 


and the meeting resumed at 3:13 p.m.) 


MR. GRIFFON: We’re going to reconvene, and 


I’m not sure we wrapped up the, let’s just 


finalize thorium here for a second, and then 


we’ll move on in the agenda. 


I’m trying to understand the question 


of source term. I’m not sure that, unless 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

186 

more evidence is presented to the work group 


that we can take this source term question 


much further. The question on the bounding 


analysis, where do we stand with the -- excuse 


me, somebody’s on not muted there. 


DR. ULSH: Hey, Jim Langsted, that’s you. 


Jim, push your mute button. 


MR. GRIFFON: He can’t hear us. 


Jim. I don’t know how to, he’s not 


hearing us. 


For the meantime those on the phone, 


I’m just going to kind of talk over. We hear 


another voice here, but just try to talk over 


him. 


So the source term question is, I 


don’t think we can go much further with it as 


far as actions unless we get more data that 


says there’s additional source term there. 


DR. ULSH: When you say the source term 


question, Mark, are you talking about 


magnesium-thorium alloy? 


MR. GRIFFON: No, I’m talking about any 


thorium, any thorium use, period, across the 


board. Did you have a comment on that? 


DR. MAKHIJANI: The thing that Tony brought 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

187 

up about the welding rods? 


MR. GRIFFON: Yeah, I’m not, I don’t know 


the extent. I think that was pretty common at 


a lot of DOE sites. 


DR. ULSH: At a lot of sites period. 


MS. MUNN: Yeah, it can’t be very large. I 


hesitate to use the word significant, but it 


can’t be, it cannot be a huge contributor. 


DR. MAKHIJANI: This is discussed in NUREG1717, and the range of intakes is pretty 


varied from small to at least not 


insignificant if you look at NUREG-1717. So 


while it would have probably been considered 


as not important at the time that it was done, 


no doubt. Again, it’s the same question. 


Until Tony told me at lunch I wasn’t, it was 


completely unanticipated. I didn’t even think 


to ask. But in the context of just asking him 


about magnesium-thorium alloy, he brought it, 


well, you were there. And since NUREG --


MR. GRIFFON: It’s going to be a complex-


wide issue, if we --


DR. MAKHIJANI: This would be a complex-wide 


issue. So I just want to raise that. It’s 


not necessarily a Rocky Flats-specific issue, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

188 

but since NUREG-1717 does cover it, we did 


write about that and cite the specific numbers 


in our report. 


DR. NETON: Is this something we should add 


to our complex-wide tracking list? It’s 


certainly not just a Rocky Flats --


MR. GRIFFON: Right, it’s not just a Rocky 


Flats, many other sites, yeah. 


MS. MUNN: My thought would be we ought to 


do that and put it to bed quickly because 


there’ll be a limited number of people who are 


involved with it. It will affect primarily 


individuals who did that type of work, and I 


wouldn’t be surprised if they aren’t fairly 


easy to identify. 


MR. MEYER: And there are a number of good 


peer review papers that estimate the dose from 


that. 


DR. NETON: So there’s no doubt we could do 


something with that. We just had heretofore 


not considered that as an exposure. I’m not 


sure all welding rods are thorium either. 


MS. MUNN: No, I don’t think so. 


MR. GRIFFON: I guess the question would 


also be, for Rocky Flats for now the question 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

189 

is could we, would there be a plausible method 


to bound, and maybe this 1717 would answer 


that. Not that I’m saying that you would have 


to do that, but if we think it’s a significant 


source or maybe a significant source. 


MR. ELLIOTT: Well, I think you’ve also got 


to look at it in conjunction with some of the 


other TIBs we’ve got out there like 


construction trades TIBs, and does the 


construction trade TIB adequately account for 


this kind of an exposure. I don’t know. 


DR. NETON: Thorium rolling rods is not 


something that we really addressed at this 


point. 


MR. ELLIOTT: I understand that, but the 


design, the exposure design in the 


construction TIB gives a very conservative, 


generous estimation of dose. 


DR. NETON: But it’s the separate nuclide 


source term that we haven’t really, we’d have 


to look at it, and it’s a good point. My 


feeling is that we could certainly bound it 


somehow. I mean, you know how much is in a 


welding rod, and you know the estimation of 


dose, and that’s where --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

190 

MR. GRIFFON: And I think for the most part 


you would expect a local exposure environment 


to the welder, right? 


MS. MUNN: Right. 


MR. GRIFFON: I don’t think we’re talking 


broad exposures to others so you could 


probably do something where you knew job 


titles and do --


DR. MAKHIJANI: I would tend to agree with 


Jim. I haven’t studied this issue. I looked 


at NUREG-1717 for magnesium-thorium alloy to 


see what was there. And actually I believe 


you brought up the question of thorium welding 


rods when we were first discussing --


MR. GRIFFON: Mel did. 


DR. MAKHIJANI: Okay, NIOSH brought it up 


anyway, and because I wasn’t aware of it, and 


I did note that there was this German study 


which I cited that has been discussed in 


NUREG-1717. So I think that this has been a 


studied issue. So I don’t know what the 


universe of data is. 


MR. GRIFFON: I think we should probably 


keep it on our radar screen in terms of 


thorium use, but my gut feeling there, and we 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

191 

should look at this further, is that if you 


have all these job cards, a lot of job card 


data. And I’m not saying the DR would 


necessarily go down this path, but we have to 


answer the question of could you estimate a 


plausible upper bound. 


And if you know welder and if you know 


something about source term as Jim said, I 


think you can probably estimate an upper, but 


that’s maybe for you to consider. But I think 


we should keep it on the radar, but I don’t --


DR. ULSH: I think maybe the question, Mark, 


is where is the appropriate context to 


consider this issue. I mean, since we’ve 


already said that in, this is not a Rocky 


Flats specific. It’s all over. So it might 


be one of those things that we handle wherever 


we’re handling overarching issues. I don’t 


know. 


DR. NETON: There’s overarching issues. The 


overarching dose reconstruction issue list is 


what we’re maintaining now. 


MR. GRIFFON: I think it rolls into a 


complex-wide question, but just in terms of 


being able to answer the issue at hand, do we 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

192 

have any SEC concerns here, I think we want to 


be able to answer that for Rocky now. So it 


might evolve into --


DR. ULSH: So do I hear an action item then? 


Would it be to consider intakes from --


MR. GRIFFON: Yeah, I think we should --


DR. NETON: I think we have to maybe sketch 


out a position of maybe not in extreme detail, 


but a position that would convince people that 


this is a tractable problem. Put it to bed 


but not necessarily come down to the actual 


dose assignments but, and then table the 


ultimate model for the overarching issues 


list. And that’s to make sure we don’t lose 


track of it because that’s going to apply to 


many other sites. 


MR. GRIFFON: I think you’ve probably got 


the pieces, too. You’ve got this NUREG, and 


you’ve got enough information about the source 


term that you can --


DR. NETON: Feel comfortable with that so 


they’re like three, four percent thorium, a 


similar amount. And let’s just vaporize it in 


the presence of the Board. 


MR. GRIFFON: We’ll add that on to the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

193 

thorium source term question and NIOSH will 


give us some kind of response on it. 


DR. MAKHIJANI: That takes care of it. 


MR. GRIFFON: Yeah, now on the other, as far 


as the other, we sort of got sidetracked with 


rolling and that was probably my fault, but so 


I think we’re pretty comfortable, when Tony 


was leaving, I think we were saying you’ve got 


some urine data and at worst case you could 


assume they’re all less than MDA. 


You’ve got something to plausibly 


upper bound it. I knew there was limited 


thorium urinalysis data. I didn’t understand 


that it covered most all those people involved 


in that limited operation. If SC&A’s 


comfortable with that, I think we, it seems 


like there’s a reasonable way to bound it, 


right? 


MR. FITZGERALD: I think again through the 


call we’ve had and this discussion, I think 


we’re pretty comfortable. And I think 


assuming there’s an upper bound analysis going 


on with the other three, I --


MR. GRIFFON: Yeah, then we’re on to the 


other three, and you’re going to, NIOSH, still 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 -- 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

194 

is going to provide some sort of empirical 


analysis on those other three. 


DR. ULSH: Yeah, I think the ball’s in our 


court. We took a shot at it and SC&A --


MR. GRIFFON: On the technical call, right. 


DR. ULSH: Right, SC&A didn’t necessarily 


agree with our approach. So we have agreed to 


take another look at --


DR. NETON: I think it’s a matter of 


parameter selection. What parameters were 


selected. 


MR. GRIFFON: You’re really looking at sort 


of a bounding analysis now, right? Is that 


what I understand? I wasn’t on the call, but 


DR. NETON: We haven’t given up on the fact 


that NUREG-1400 isn’t applicable, although we 


agree that there are parameter selection 


issues there that would maybe not make it 


quite as conservative as we maybe heretofore 


thought. We need to look at it a little 


closer. 


MR. GRIFFON: So you’ve got those actions? 


DR. ULSH: Yes. 


MR. GRIFFON: And the only additional thing 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

195 

is the welding rods, and that question. 


All right, moving passed thorium at 


3:26, plenty of time. This is where we speed 


up. I have next --


Do you want to put these two items 


together, Joe? 


MR. FITZGERALD: Yes, I think so. 


LOG BOOK ANALYSIS AND DATA INTEGRITY AND SAFETY CONCERNS
 

MR. GRIFFON: Log book and data integrity. 


MR. FITZGERALD: Right. 


MR. GRIFFON: So log book analysis and 


before I had safety reports, but Joe says that 


there wasn’t really outstanding actions on 


that. I don’t know if we really need an 


update. 


MR. FITZGERALD: The safety concerns piece, 


and certainly, Kathy’s on the phone as well. 


We certainly finished first and distributed it 


to the work group back in November. 


Certainly, I think maybe the easiest thing is 


for Kathy to just sort of capsule all three, 


the data integrity examples, log book review, 


and maybe just provide a short overview of not 


the specific details but the sort of bottom 


line conclusions in the SEC context and just 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

196 

sort of walk the work group through. Would 


that help? 


MR. GRIFFON: That would be helpful, yes, so 


we’re going to log book analysis, data 


integrity and safety concerns. 


MR. FITZGERALD: Yeah, they overlap, and I 


think it would probably be helpful not to 


separate them out even though that’s how we 


issued them. This way it could be digestable. 


MR. GRIFFON: Kathy, if you can give us a 


fairly quick summary of each of those items, 


then maybe we can get into some more detail on 


the log book question. 


MS. DeMERS (by Telephone): I will try. If 


you remember in the petitions, a lot of people 


brought up a concern that that something was 


wrong with the badge --


MR. GRIFFON: Hold on, Kathy, you might have 


to speak a little louder. Are you on a 


speaker phone? 


MS. DeMERS (by Telephone): No, no. 


MR. GRIFFON: Ray’s having a little trouble 


hearing you so go again. 


MS. DeMERS (by Telephone): If you remember 


from the petition, several people brought up 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

197 

concerns about receiving years when they were 


working in high dose rate areas, and we were 


trying to get to the bottom of this in our 


review with the safety concerns and the log 


book review. The (inaudible) of (inaudible) 


NIOSH most of those from the list of probably 


4,000 safety concerns. And NIOSH looked at 


them and evaluated them for their relevance to 


the SEC petition. And SC&A was asked to 


evaluate their evaluation. 


And in general, there was good 


agreement, but there were some areas where 


there was not agreement. For example, there 


were some disagreements regarding how they 


handled external dosimetry investigations. 


There was some disagreement in relation to 


some of the assertions regarding individuals 


involved with the concern that said basically 


I got a zero. I don’t believe this happened 


in X,Y area; the dose rate was X, Y, Z. 


This kind of spills into the data 


integrity example. The basic answer was that 


the areas were closest at the maximum dose 


rate but that that was not necessarily the 


dose rate that the individuals were receiving 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

198 

from where they were standing. Now we looked 


at a couple of these situations and that 


explanation doesn’t really pass with us. 


There’s got to be more to this because it’s 


been brought up in the safety concerns. It’s 


been brought up multiple times in the comments 


in the data integrity section. We haven’t 


really found I would say conclusive evidence 


of a systemic problem, but it sure does come 


up frequently in different formats. 


And with respect to assigning zero 


when people were in high dose rate areas, is 


it that there should be some further 


investigation into that? And one of the 


contentions was that the people who were 


communicating those dose rates in the petition 


were not knowledgeable of the dose rate levels 


and how they’re measured. So in fact, most of 


these people were radiological control 


technicians so they did have the knowledge to 


interpret the readings. In fact, they were 


responsible for recording them. 


And with respect to dosimetry 


investigations basically what we have is the 


word of the RADCON staff that they occurred. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

199 

We have a few, actually, I think only one log 


book entry that said he went out in the field 


and tried to figure out the dose for 


(unintelligible) because the badge was 


damaged. So either these investigations 


didn’t happen in the field or they weren’t as 


significant to be recorded in the log books or 


someone else did them if we assume that the 


RADCON personnel are correct. Basically, we 


have no paper evidence that these occurred 


prior to the mid-‘80s. So that’s kind of 


where we stand on that. 


One of the things that I noted in the 


data integrity analysis was that you really 


had to go in and understand the entire 


comments, and I ended up re-describing quite a 


number of comments as a result. And I felt 


that NIOSH wasn’t really answering the 


question or the comment that was brought up by 


the person providing the affidavit or the 


comments. Those were really the two major 


issues where there was some disagreement 


amongst the safety concerns and data integrity 


examples. 


Another thing that I noticed with 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

200 

respect to the data integrity example is that 


they missed about seven or eight comments 


which were quite important as they went 


through and captured comments from the 


Advisory Board meeting in Denver. And I went 


ahead and added those, and NIOSH, of course, 


had not had a chance to respond to them so 


we’re not quite sure where we stand on those 


seven or eight comments. 


MR. GRIFFON: I think we did say that for 


the safety concerns report, I think we pointed 


out at one of the previous meetings that there 


was some individual items that there was 


disagreement, but at least as a work group we 


told NIOSH don’t, we don’t want you to, we 


don’t expect you to further investigate these 


individual cases. So that may be, that may 


have been our decision. 


For the data integrity, I get these 


things confused sometimes, these three or four 


kind of do overlap a little bit in my mind. I 


can’t remember if there were specific items 


that we have asked for follow up on or --


MR. FITZGERALD: Well, this was the specific 


73 page, very detailed compilation that NIOSH 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

201 

put together. 


MS. DeMERS (by Telephone): This came out or 


this came out in mid-January, very recently. 


MR. FITZGERALD: August, yeah, right, 


August. 


MS. DeMERS (by Telephone): A lot of this 


concern is raised with respect to the safety 


concerns are also raised in the data integrity 


example response. And it’s almost more 


beneficial to address them in terms of the 


data integrity examples. 


MR. FITZGERALD: Yeah, Kathy, this is Joe. 


I think it’s fair to say though for both of 


those documents that we do have, in fact, 


interpretive differences on the specific cases 


within the safety concerns as well as in the 


data integrity examples. And I think you 


added that there were maybe seven or eight 


examples that may have came out at the Denver 


meeting that were not necessarily in the data 


integrity compilation that we’ve added for 


comment that we have since provided on January 


3rd to NIOSH for review. But I think the 


overall conclusion again with those 


differences that we weren’t able to 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

202 

conclusively demonstrate a pattern or systemic 


problem, any evidence of fraud necessarily in 


the broader sense. Is that fair? 


MS. DeMERS (by Telephone): We were not able 


to conclusively identify fraudulent data 


entries with respect to those two reviews. 


However, you need to be aware that there are a 


lot of examples, and I guess you will have to 


think about what the threshold is for 


determining if that, if you’re going to accept 


NIOSH’s explanation in regard to that. 


MR. GRIFFON: Hold on, Kathy, Brant wants to 


reply. 


DR. ULSH: But at the end of the day, as Joe 


said, I think you discovered no evidence of 


fraudulent data entry. I mean, it’s SC&A’s 


position that you have discovered no evidence 


that would support that. Is that correct? 


MS. DeMERS (by Telephone): I’m not 


disagreeing with that. I would emphasize we 


don’t have any conclusive evidence. 


MR. FITZGERALD: We can’t find it. 


DR. ULSH: Well, okay, I guess the other 


part of that question then is how hard have we 


looked. And I would put on the table that we 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

203 

put out a 73-page document and considered 


every concern expressed at the Board meeting 


with the exception possibly of seven that we 


might have missed. We’ve looked at 5,000 


safety concerns. We looked at -- what? -- 60 


log books? And if you don’t find something 


after all of that, can’t you draw some kind of 


a conclusion from that? 


MR. ELLIOTT: I think we’ve surpassed the 


threshold here. In a world of limited 


resources I understand and appreciate the need 


to respond to these individual allegations and 


assertions that were made in these affidavits. 


But I think we’ve more than enough addressed 


this issue. 


MR. GRIFFON: That’s why I didn’t ask for 


any follow up from NIOSH on these items 


because I think at this point it’s one of 


those questions, like with Y-12. I mean, 


we’ve got a bunch of prongs, and we’re going 


to look at the weight of this evidence --


MR. FITZGERALD: And I think you have --


MR. GRIFFON: Everything here points to at 


the worst I think inconclusive is sort of 


where SC&A is weighing in. At the best it is 

1 -- 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

204 

MR. FITZGERALD: And you have the reports, 


and in a sense we were very careful I thought 


about how to lay this out. And I think our 


conclusions are not inconsistent with what 


you’ve said that we’ve looked hard, that we’ve 


looked far, and we did find a number of 


specific cases where we were concerned. But 


in the final analysis there wasn’t any 


evidence of fraud or a systemic pattern that 


we would be concerned about and that’s based 


on what we did look at. 


MR. GRIFFON: How about for the log book 


analysis, the last piece? 


MR. FITZGERALD: Well, that was the most 


recent, and I realize that was because of the 


Privacy Act review that got over kind of late. 


That got over the 19th, but again, Kathy, do 


you want to summarize pretty much, that has a 


long history. Maybe you can briefly summarize 


where that came from way back when. 


MS. DeMERS (by Telephone): Back in March I 


started work with the Rocky Flats records 


folks to pull back some records, primarily 


dosimetry and procedures, processing logs, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

205 

that type of material. And then I went and 


visited Rocky Flats and talked to the 


petitioners on the 27th or 29th of March. And 


in the course of talking to the petitioners 


they indicated that the log books may disagree 


with the dosimetry records. 


And so I went back to the records 


folks, and I said can you search for RTC log 


books, contamination control log books, et 


cetera, and provide me with the results. And 


of course, they didn’t have time to pull that 


from the Records Center in one day. So they 


weren’t available for review when I was there. 


The plan was to take some of these 


affidavits and see if we could locate the 


person in the log books and follow through the 


dosimetry processing logs and make sure that 


they didn’t have a damaged dosimeter or some 


sort of situation where a zero would be, 


situations that would require a dosimetry 


investigation. Then we were to go to the 


actual dosimetry records and do a comparison 


back to the original number in the log book. 


Well, what happened when we went 


through several log books was that we couldn’t 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

206 

find these particular people. So we decided 


to evaluate people with dose information that 


were in the log books. But let me back up 


here a little bit. 


The original intention with the second 


request to Rocky Flats for the log books was 


to have them scanned and then I was going to 


go through and walk through this process. In 


April the working group decided to turn this 


over to NIOSH. And we went through several 


iterations of trying to explain, you know, 


what my original plan was and how they might 


implement it. But in the meantime there were 


these log books sitting there. 


And when it was turned over to NIOSH, 


they were to go through those log books, and 


there were boxes of them. And at least say 


this will be useful; this will not. And if 


there were log books that were useful, they 


were to scan them and provide a copy also to 


SC&A and the working group. 


Kind of on a separate path, ITT was to 


make a very, very specific request of Rocky 


Flats in the process of my own review being 


centered around identifying the main 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

207 

supervisors over the buildings that may have 


had log books. They centered around the 1969 


fire. So those ’69 field log books were not 


intended to cover a large range; whereas, the 


initial log books that I had asked the records 


people to pull, were. As a matter of fact 


they ranged from 1957 through 1996. 


In July NIOSH came back with a review 


of the famous Kittinger log which spans from 


’58 or ’56 through ’68. And they extracted 


quite a number of individuals from the log 


book and compared the doses in the log book 


back to the health physics file. A lot of 


these were external dosimetry results. 


Unfortunately, they were for a cycle for some 


of them rather than a quarter when the health 


physics file really had a quarter. 


So we determined whether they were an 


exact match or consistent, and we had no 


problems with the exact matches or the 


consistent matches. Then they came out with ­

- and Brant, you’re going to correct me if I’m 


wrong -- with about 94 percent agreement. 


DR. ULSH: Yeah, that’s about right, Kathy. 


MS. DeMERS (by Telephone): There were 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 -- 

21 

22 

23 

24 

25 

208 

others that they didn’t have files for, and 


they had to go back to Rocky Flats and request 


them. And at that point, that review, there 


was a discussion about the fact that, well, 


that probably knocked people out of that log 


book. But that log book doesn’t represent the 


entire span of time, and it also doesn’t 


represent the uranium area or the non-


plutonium area. 


DR. ULSH: Wait a minute, Kathy. Are we 


talking about the Kittinger log book or are we 


talking about --


MS. DeMERS (by Telephone): Yes, the 


Kittinger log book. 


DR. ULSH: Oh, okay, the Kittinger log book, 


yeah, I reviewed half of the data --


MR. GRIFFON: That first one. 


DR. ULSH: Yeah, that first one. I don’t 


remember the number, but I found a pretty high 


MR. GRIFFON: Agreement. 


DR. ULSH: -- level of agreement, yeah. The 


94 percent number though is for our overall 


log book analysis. We found overall we found 


94 percent agreement. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

209 

MS. DeMERS (by Telephone): That’s pretty 


good agreement with the Kittinger logs to go 


back and look at consistent results and exact 


results. 


However, 19 of these people from the 


Kittinger log were picked up in the second 


review which was to cover from 1969 through 


the ‘90s. 


MR. GRIFFON: Right, this is the final 


report that you issued to us. 


MS. DeMERS (by Telephone): Right. 


MR. GRIFFON: The log book review, yeah. 


MS. DeMERS (by Telephone): I kind of 


segregated them into two separate reviews. 


But there were a couple that got dropped in 


the transition, but that was primarily because 


we decided enough was enough with that log 


book. 


There was a second review that was 


done, and like I said it was supposed to cover 


1969 through the 1990s. In July, NIOSH was 


asked to come up with a sampling plan for how 


they were going to sample further log books, 


and these log books were to cover various 


processes onsite including plutonium and non­
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

210 

plutonium areas. 


And what they came back with was not a 


sampling plan but a review of a subset of 


those 50, and that’s an approximate number, 


log books that I had retrieved and subsequent 


from the original log book request. And as I 


said these were more specific to particular 


time periods, and they were targeted at the 


RADCON field supervisors. 


MR. GRIFFON: Yes, so now we’re on the final 


report from NIOSH. And what time period did 


that cover, Kathy? 


MS. DeMERS (by Telephone): That covers from 


1957 through 1971, and that included 20 


urinalysis log books and 16 field log books. 


As a matter of chance there were log books 


from the earlier years from the uranium area, 


and there were log books for select years for 


the plutonium area. And that was primarily 


because the supervisors that I had requested 


were from all over the plant. 


MR. GRIFFON: Is that, I’m thinking 20 


urinalysis logs, is that accurate? 


DR. ULSH: I don’t know how many urinalysis 


logs there were. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

211 

MR. GRIFFON: Anyway, we can do that later. 


Go ahead, Kathy, sorry. 


MS. DeMERS (by Telephone): Well, again, 


various items were extracted from the field 


log books, urinalysis results, whether a 


person was involved in an incident and was 


sent to the in vivo counter. I think there 


was in one count and some external dosimetry 


results. With respect to the log books, they 


actually select a claimant from within the log 


books and made a comparison of that urinalysis 


log book to the health physics file, and in 


general, we had compared the results to the 


health physics file, which I call the hard 


copy record here, 94 percent of the bioassay 


results agreed or were consistent. 


In the case of in vivo counts, and a 


lot of times they will just reference that 


they sent somebody to the in vivo counter so 


we were virtually just looking for evidence 


that they had an in vivo count. Eighty-six 


percent of the entries polled agreed with what 


was being stated in the log books. There were 


four individuals where we didn’t have files 


available, health physics files available for. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

212 

And the agreement with the dosimetry results 


listed in the log books versus the health 


physics records were fairly good. 


One log book that they selected 


individuals from was called, I’m going to 


refer to it as the 1966 through 1969 Special 


Analysis Log Book. And this had bioassay 


results for radionuclides other than uranium 


and plutonium. And they polled 24 people I 


believe out of that log book, and again, 


compared the log book results back to the 


health physics file. We did not have the 


means available to do this comparison so we 


were not able to verify their results. But in 


their write-up it indicated that they did not 


get agreement in eight cases out of the 24. 


MR. GRIFFON: That’s for the special 


radionuclide log? 


MS. DeMERS (by Telephone): Yes. 


We also did a comparison of the log 


book results to the HIS-20 external database 


and the urinalysis database, and this is where 


we started to discover some issues. 


We had 68 percent agreement between 


the bioassay results and the log versus the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

213 

health physics. Let me back up. First is the 


data available in HIS-20, and the remainder of 


those people were not showing up in HIS-20. 


So I went and I scanned the people who were 


not showing up in the HIS-20 to determine 


whether they had zero doses or positive doses. 


And there was a mixture so we’re not just 


talking about people who didn’t have positive 


urinalysis data in this case. 


MR. GRIFFON: This could be important back 


to our discussion on coworker models 


obviously, that last point. 


DR. ULSH: (Unintelligible). 


MR. GRIFFON: Yeah, and then there could be 


explanations if they retired before ’77 or 


whenever. We know, we know the explanations. 


Go ahead, Kathy. Was that it for --


MS. DeMERS (by Telephone): There are two 


other things. 


The problem was not as bad with the 


HIS-20 data, between the HIS-20 database and 


the external data, but it was still there. 


And the final concern that we had was 


going back to the original log book request 


that I made of Rocky Flats of the RCT logs, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

214 

the contamination logs, et cetera, which got 


turned over to NIOSH, and there’s no 


indication by NIOSH that whether those log 


books were useful or not for the SEC petition 


review. And they have indicated that they 


reviewed 450 boxes of documents; however, 


we’re looking at 59 log books here and there’s 


a delta there that SC&A doesn’t know anything 


about. 


We don’t know if those log books are 


useful or whether (unintelligible) is not 


having any individual data in it. We don’t 


know the contents of these 450 boxes, and 


there’s a concern that they concentrated on 


these 60 log books that are on the O drive 


which were not representative of the ’69 


through ’99 timeframe. 

MR. GRIFFON: ‘Ninety-two. 

MS. DeMERS (by Telephone): I think Arjun 

said through --

DR. MAKHIJANI: Two. 

MR. GRIFFON: ‘Ninety-two. 

DR. MAKHIJANI: Early ’92. 

MS. DeMERS (by Telephone): So we were left 

wondering, okay, what about these other time 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

215 

periods. Did you find any log books in here? 


What about the representativeness of what you 


did choose to review? And this kind of goes 


back to the sampling plan and the fact that 


the sampling plan was not produced but instead 


this review was produced. 


MR. GRIFFON: Kathy, I guess I just want to, 


I mean, from my read on this two things jumped 


out to me to follow up on anyway. One was 


this question of, you know, we did, there was 


an action item to do a sampling plan. I 


understand. You did a final report, but the 


real question, at the end of the day we just 


want to make sure we cover all time periods of 


concern and all potential, all operations of 


concern. So if we, I think it does look like 


– is it from ’71, you know, ’72 through ’92 


seem to be not represented very much in this 


review. 


DR. ULSH: And the reason that they’re not 


represented, Mark, is that log books that 


contained the kind of data that we were 


looking for did not exist after ’71 or ’72 and 


they went to an electronic --


MR. GRIFFON: Yeah, we know there weren’t 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

216 

any urine logs, and I don’t know if there are 


any other logs that --


DR. ULSH: The same with external, now if 


there are other logs --


MR. GRIFFON: No, not just, yeah, okay, I 


mean, the other field logs that would have had 


some --


DR. ULSH: There are other logs, the RCT and 


contamination log books that exist into the 


later time periods, but as we discussed at 


previous working group meetings, those logs 


are not the kind of logs that contain the 


useful information that we needed for cross 


walking. We talked about that, that there 


wasn’t a lot of information in those logs. 


MR. GRIFFON: We talked about the foremen 


logs not being very useful. I don’t remember 


talking about the RADCON or DECON logs. Maybe 


we did. 


DR. ULSH: I think we did, didn’t we? 


MR. GRIFFON: But I thought the foremen logs 


were the ones that we were --


MR. FITZGERALD: I think it was clear that 


the foremen logs were not useful in any sense, 


but I think it was --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

217 

MR. GRIFFON: I mean, I haven’t looked at 


these things so if you reviewed and --


DR. ULSH: Well, I’m trying to think back 


from months ago, but I think I presented an 


example of not just a foremen log but I 


thought a contamination control log book. I 


don’t know about RCT. I can’t remember. It’s 


too far back, but there just wasn’t, that they 


were very, very data poor. I didn’t, I don’t 


think I saw any data in there. 


MR. MEYER: Oh, we looked at RCTs. 


DR. ULSH: We looked at RCT logs? 


MR. MEYER: Yes. 


DR. ULSH: Okay. 


MR. MEYER: Microfilm. 


DR. ULSH: Yeah. 


MR. GRIFFON: With microfilm, too, you said? 


DR. ULSH: There are some things here that I 


do need to respond to. 


MR. GRIFFON: So just let me, so that’s one 


question, and I think you’ve responded to it. 


The only other thing that jumped out at me 


from this review is the tie back into the HIS20 database. And I think there are some 


possible explanations for some of these 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 -- 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

218 

things, but I wanted to ask did we, I thought 


at some point early on in this process you all 


did an analysis of hard copy records versus 


HIS-20 and came out with very strong 


agreement. Was that with log books or what 


were you comparing that, that point? I think 


it was RAD files with HIS-20. 


DR. ULSH: Wasn’t it TLD worksheets? 


MR. MEYER: TLD worksheets and then I think 


MR. GRIFFON: So it was external or was it 


both? 


MR. MEYER: Yeah, external. 


DR. ULSH: External. I presented those 


results at the April Board meeting when we 


gave our ER presentation. I don’t remember 


the exact numbers. But, yeah, I’m sure it was 


TLD worksheets versus HIS-20. And then I 


can’t remember about internal. 


MR. MEYER: We did some internal, too. 


MR. GRIFFON: And TLD worksheets would have 


been beyond the, I forget what time period you 


covered. We’ll have to resurrect that 


document, but it could have been started in 


the early ‘70s, right? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 -- 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

219 

DR. ULSH: Yes. 


MR. GRIFFON: So it would have been through 


the ‘70s, yeah. 


DR. ULSH: I don’t know. I can’t remember 


the time period that the ones we looked at 


covered. I don’t remember. 


MR. GRIFFON: I mean I think we might want 


to reflect on that piece because that may help 


us, you know, like I’ve said again and again, 


we’ve got several prongs, no one item is going 


to cover this perfectly. 


Did you write that, Craig or was that 


MR. LITTLE: Pardon? 


MR. ELLIOTT: Was that yours or, you wrote 


that, right? 


MR. LITTLE: Yeah. 


MR. GRIFFON: I can’t remember when it was 


provided. I think it goes back to --


MR. ELLIOTT: Or when you issued it? It was 


before the April meeting. 


MR. GRIFFON: Yeah, I think it was in March 


at the Boston meeting that that first came 


out. Anyway, we might want to reflect back on 


that in comparison to this. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

220 

Go ahead, Brant. That was my two. 


UNIDENTIFIED (by Telephone):
 

(Unintelligible) some of that information is 


captured in OTIB-58. 


MR. GRIFFON: OTIB-58 has that reference? 


UNIDENTIFIED (by Telephone): Yes. 


MR. GRIFFON: Okay, we’ll look in OTIB-58 


for that reference. 


UNIDENTIFIED (by Telephone): It’s Section 


Six. 


MR. GRIFFON: Section Six, thank you. 


MS. DeMERS (by Telephone): Let me clarify 


something. In the log book analysis we did 


not go from HIS-20 to the health physics file. 


We went from the log book to HIS-20. 


MR. GRIFFON: I understand, Kathy. I’m just 


saying that there was another type of 


analysis. I was getting a little history 


lesson. I couldn’t remember if they looked at 


log books or if they looked at TLD worksheets 


as it was. 


DR. ULSH: Okay, well, I’ll make this brief. 


It might have been Kathy’s original plan to 


look at the log books as they surrounded the 


affidavits, but we were never tasked by the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

221 

working group with focusing on, in any way, on 


the particular individual instances listed in 


the affidavits. In fact, we were tasked to do 


a random sample which is exactly what we did. 


This analysis was never meant to be 


exhaustive. It was never meant to look at 


every log book that existed. What we were to 


do was to come up with a random sample. 


Now in terms of why we didn’t look at 


the log books past 1971 as I’ve already 


stated, the types of log books that were most 


useful, the urinalysis log books primarily, 


and also the ones that contained a lot of 


external dosimetry data did not extend past 


1971, ’72, right around the time when they 


started going to electronic recording. So 


those log books simply don’t exist. 


Now there are, as I said, RCT 


contamination control various kinds of log 


books, but those are of the type that we 


determined and discussed with the working 


group that they were not, they didn’t contain 


the kind of data that we needed to cross-walk 


to draw a conclusion. 


Now Kathy mentioned the 60 log books 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

222 

that are on the O drive, and she mentioned 


that we reviewed a subset of them. I don’t 


believe that is accurate. I believe that we 


reviewed every log book that has been posted. 


In terms of those 60 log books, I mean it is 


presumed that those 60 log books were 


requested by SC&A because they related to a 


specific concern in the affidavit. So to that 


extent I think that our analysis is even more 


targeted. I mean if what Kathy’s saying is 


true that those log books supported the 


particular concerns that she had --


MR. GRIFFON: Let’s step back and remember a 


meeting where we talked about the overall goal 


of this. There is specific references in the 


transcripts where we said a lot is derived 


from some of the affidavits and comments, but 


we’re really, our goal here is the SEC, the 


entire population covered by the SEC. So we 


want to do a plan that would cover all the 


decades, ‘50s, ‘60s, ‘70s, ‘80s, up to ’92. I 


think we cut it off because the D&D was kind 


of a separate thing, and different types of 


operations, relevant operations. 


DR. ULSH: Right, uranium and plutonium. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

223 

MR. GRIFFON: Yeah, I don’t particularly 


remember. I’m not doubting that you said 


this, but I don’t particularly remember. I 


remember the foremen’s logs being dismissed 


because we had several examples of those. But 


the other stuff I guess I don’t remember that 


as well. I don’t doubt that you mentioned it 


in a meeting. We’ve had quite a few meetings. 


MR. MEYER: Well, an example I guess of the 


RCT log book is the first notice of the ’69 


fire was in an RCT log book, and we did talk 


about that. So that was one of them that --


MR. GRIFFON: Yeah. 


MS. DeMERS (by Telephone): I want to 


clarify something here. The original plan was 


to target people who issued affidavits, but we 


found that we could not find those specific 


people in the log books. So we expanded it to 


people with data in the log books. 


MR. GRIFFON: Okay. But anyway, I’m just 


saying we also expanded it to cover the SEC 


petition as a whole. So I mean I guess the 


question would be, you know, it sounds like 


you reviewed, you know, you’re telling the 


work group that you’ve reviewed other of these 

1 

2 

3 

4 

5 

6 

7 -- 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

224 

other RCT or DECON log books, and you’ve made 


determinations that there’s just nothing there 


worth, nothing to cross-check basically. 


DR. ULSH: We looked at the log books in 


their hard copy form to determine whether it 


was worthwhile to scan them because as we said 


MR. GRIFFON: Well, that was my next 


question, were they available in scan so we --


DR. ULSH: There were 450 boxes of log 


books, and this is the most resource-intensive 


part of the whole operation is scanning these 


things. So we looked at them before they were 


scanned, before they would have gone to 


scanning to see if it was worthwhile to do 


that. And we determined that it really 


wasn’t. So everything that was scanned was 


posted on the O drive. There are no more log 


books scanned that we are sitting on or hiding 


or anything like that. You have everything 


that we had scanned. 


MS. DeMERS (by Telephone): We understand 


that. 


MR. ELLIOTT: And we don’t see the utility 


in going forward and looking, scanning the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

225 

other log books because they don’t bring 


anything to bear. 


DR. ULSH: Exactly. 


Now in terms of HIS-20 versus the 


health physics files, we focused on the health 


physics files because remember that the 


original concern was is the data that’s being 


used for dose, individual dose reconstructions 


reliable or are there some problems here that 


would indicate fraud or whatever the concerns 


were. So we thought it was most relevant to 


go to the RAD files themselves even though 


that was, you know, a bit more work. 


But there was another motivation for 


doing that, and that is the known limitations 


at this point. We talked about the in vivo 


issues with HIS-20, and we’ve also talked 


about what Mark mentioned that individuals who 


terminated employment prior to 1976 or seven, 


something like that, their data was not 


initially loaded into HIS-20. Some of it was 


later restored if they were part of the 


medical recall program but certainly not all. 


And therefore, we figured that it 


would be most informative for those reasons to 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

226 

look at the data in the hard copy RAD file. 


That’s what’s used in individual dose 


reconstructions. That’s why we didn’t --


MR. GRIFFON: That’s fine. This is why we 


go down this path all the time, but that’s 


what’s used in many of the individual dose 


reconstructions. I mean you have coworker 


models for a reason. You’re going to use them 


eventually. 


DR. ULSH: Yes, yes, we did. 


MR. GRIFFON: And there was a third reason. 


It’s because the work group tasked you to look 


at the individual RAD files. We didn’t ask 


you to look at the database stuff. We wanted 


you to look at the RAD files. That’s correct. 


I don’t disagree with that. 


DR. ULSH: And you know I’ve got to go back 


to, I mean if you’ve never taken part in any 


of the lead up to this meeting, you would 


think from listening to the summary here that 


there were a lot of big important issues that 


SC&A did conclude at the end they didn’t find 


anything, that indicated systematic problems. 


And I go back to something that John Mauro 


said when I presented the first results from 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

227 

the Kittinger log book. I reviewed half the 


data points in it and John said something 


like, you know, if it walks like a duck, and 


it quacks like a duck, you know, there’s 


really no reason to go look at the other half 


of this log book. 


And I would extend that argument here. 


I mean, there are some concerns, I guess, 


being expressed that we didn’t look at a 


representative sample. My question is, I 


mean, if these log books included at least, 


the log books that Kathy identified that 


correspond to places where the petitioner was 


saying that there were issues, and we’ve 


looked at these, and we haven’t found, we 


found 94 percent agreement, what are the odds 


that the other log books that exist contain 


some problem that we haven’t come across. 


That’s analogous to the argument that John 


Mauro made after the Kittinger log. 


MR. GIBSON (by Telephone): Brant, this is 


Mike. Can I just cut in for a minute? You 


know, I take a little bit of exception to the 


way you just characterized what you just said, 


if it walks like a duck, quacks like a duck, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

228 

it must be a duck. 


DR. ULSH: I didn’t say that. John Mauro 


said it. 


DR. MAURO (by Telephone): No, I didn’t 


quite say that. I said this house is clean. 


DR. ULSH: Oh, yeah, something about rotten 


in Denmark or --


MR. GIBSON (by Telephone): I just want to 


say that, you know, having lived in the DOE 


world if it walks like DOE, and it talks like 


DOE, you can’t be assured of nothing. 


DR. ULSH: Mike, my point was if we’ve 


looked in a large sample of log books, and we 


haven’t discovered an issue, what is the 


likelihood that we’re going to find an 


undiscovered problem if we look at more 


similar log books. That was my point. That’s 


all I’m saying. I’m not saying anything about 


DOE’s credibility or anything like that. 


MS. DeMERS (by Telephone): This is Kathy. 

Can I make two requests? 

MR. GRIFFON: Sure. 

MS. DeMERS (by Telephone): One would be 

that we get the names associated with those 


pulled from the Special Analysis log books so 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

229 

that we can include that in our review. And 


the other issue is can NIOSH document what 


happened in their review of these log books 


that were not scanned. 


MR. GRIFFON: I think you’re documenting to 


an extent on the record here. I think Brant’s 


documenting it to an extent. I mean, I don’t 


know if you can describe that better how you 


got those 450 boxes I think is the question. 


You looked at how many and you determined that 


they weren’t very useful for in terms of, I 


mean, I think that --


DR. ULSH: I can’t say off the top of my 


head. If that’s something you want, we can do 


that. 


MR. GRIFFON: Yeah, just a description of I 


think is what --


MR. FITZGERALD: Well, the presumption, too, 


then is the balance of those log books were in 


fact perhaps bridged these time periods so we 


talked about they were the basis for the 


sampling plan so that’s the other kind of 


implication although I’m not sure that’s, 


whether you confirmed that or not. Because we 


don’t know what’s in those boxes. I think 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

230 

that’s what she’s saying. 


DR. ULSH: Let me clarify. I misspoke 


earlier when I said that we reviewed 450 


boxes. We pulled 450 boxes, and we looked 


through those for log books, and it wasn’t 450 


boxes full of log books. I don’t want to 


imply. 


MR. GRIFFON: So you looked through log 


books, and you sampled from, but you can give 


us a little description of that field 


activity. And the first item I think you can 


provide us with those names for the Special 


Analysis log book. Were they in the report? 


I don’t know if --


DR. ULSH: That’s a very, I’m familiar with 


that log book. I’ve looked at it a lot. 


There are, I think, maybe 40 individuals in 


that log book. In terms of identifying the 


exact individuals that were in there, we’ll 


find out. 


MS. DeMERS (by Telephone): What I’m 


referring to is the individuals you did the 


comparison for. 


DR. ULSH: Okay, yeah, I’ll try to track 


that down. But I will point out though that 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

231 

that log book contains results, urinalysis 


results for what we’ve categorized as other 


radionuclides. I’m thinking of, you know, 


curium, neptunium for which SC&A’s already 


agreed that there’s not an issue with those 


radionuclides. 


MS. DeMERS (by Telephone): Well, this is a 


matter of data completeness and not a matter 


of whether people were monitored. 


DR. ULSH: I’ll get the names. 


MR. GRIFFON: I’m not sure, you know, this 


question of the, this crops up in many of the 


pieces we’ve done. It seems to me after ’69 


there’s nothing to look at to verify. That’s 


a concern I have, and you know, there’s no log 


books. There’s no, I’m curious to maybe 


understand this, and I know it was brought up 


at a previous meeting. I think Gene Potter 


might have brought this up. That after ’71 or 


whatever year it was. I’m not sure of the 


exact year. You went to this electronic entry 


with the data. There was no urine logs, or 


they just live entered. But I don’t know 


that, I mean, did they have, what types of 


computers were in place at that point to do 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

232 

live entry or was it card entry or was it, I’m 


surprised there’s no hard copy record at all. 


MS. MUNN: It would have had to be card 


entry. It was Sperry Rand. That’s why I was 


there. 


MR. LITTLE: I don’t think it’s quite 


accurate to say there were no log books after 


1971 because there were log books clear up 


into the D&D era for certain things. 


MR. GRIFFON: No urine logs it was saying. 


MR. LITTLE: Well, not that I’m aware of. 


MR. GRIFFON: Right, no urine logs. 


MR. LITTLE: And we looked at log books of 


various titles. We looked through reams, 


literally, microfilm, boxes and boxes of 


microfilm. 


MR. GRIFFON: I mean, those urinalysis logs 


were very helpful because you had obviously 


quantitative data to compare against with 


individuals, but then it stopped in ’69 or ’70 


or whatever. And the question is beyond that 


what happened? Apparently there’s no hard 


copy record to compare against after that. 


That’s your experience. I’m not saying, if 


it’s not there, it’s not there. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

233 

MS. MUNN: Speaking from memory not at this 


site but what was going on in the computer 


world then, it had to be, you had card decks 


and mag tape. That’s what you had. 


MR. GRIFFON: It wasn’t laptops. 


MS. MUNN: Yeah, no laptops and certainly no 


Blackberrys. It was, but direct entry would 


have probably been card stock. But also from 


my memory one didn’t maintain cards for a 


long, long time. After you had, after you 


transferred them to mag tape, you usually 


discarded them. 


MR. LITTLE: Yeah, the (inaudible) becomes 


the record at that point. 


MR. MEYER: The mag tape might still exist 


at the archives. 


MS. MUNN: Might. 


MR. MEYER: We’d have to re-invent the tape 


drive. 


MS. MUNN: Yeah, and finding the platform is 


something else again. If you can find the 


tape, you can’t find the platform. 


MR. GRIFFON: Well, some of the sites 


certainly had the card data, saved, archived, 


but I guess we just didn’t have it here. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

234 

DR. ULSH: I don’t know, Mark, I don’t know 


that we specifically looked for card --


MR. GRIFFON: You haven’t found it I would 


say. 


DR. ULSH: We don’t have it in our 


possession. 


MR. MEYER: We haven’t encountered them. We 


haven’t looked at, I mean, my experience at 


Oak Ridge was that at that point it would have 


been line-printed output and the cards by now 


certainly would have been discarded. It would 


be just a massive ... 


MR. GRIFFON: So I don’t know, you have this 


log book report. You haven’t given us a 


response to this or did you? 


DR. ULSH: No, we haven’t given a response 


mainly because the conclusion at the end was 


that they didn’t see any SEC issues. 


MR. FITZGERALD: Remember that the charter 


for the work group was to review what NIOSH 


had evaluated. We, in fact, did so and based 


on that scope I think our conclusion wasn’t, 


we didn’t see any systemic issues. I think 


the only asterisk we’re adding is that we have 


some reservations about the record as we’ve 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

235 

discussed, and we certainly didn’t have any 


information on the way the boxes were used. I 


think some of this information is now 


forthcoming. So that’s kind of where we are. 


MR. GRIFFON: Which I don’t know, you know, 


that’s what I’m looking for is another prong 


that sort of fills that gap of the ‘70s and 


‘80s, you know. I mean, it seems like, at 


least in my experience of what I’ve seen on 


post, I’m limited to what I can view 


obviously, but the log books look like they 


only go into the early, I mean the Health and 


Safety reports also look like they, unless you 


have later ones that go through the ‘70s into 


the ‘80s. 


DR. ULSH: I haven’t located any beyond ’71. 


MR. GRIFFON: And my experience is that on 


most of the sites the utility of those safety 


reports decreases as time goes on. There’s 


more data in the early ones and less data in 


the later ones. There’s more language in the 


later ones but less data. It’s just the way 


they, yeah, maybe for legal reasons, whatever. 


But this is not inconsistent with what we ran 


across at Y-12 actually that we sort of in the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

236 

‘70s we started having difficulty with 


anything to compare. 


MR. FITZGERALD: Yeah, we can’t conclude 


anything beyond the scope that we looked at. 


But what we did look at certainly we didn’t 


see a systemic. 


MR. GRIFFON: I guess at this point the only 


outstanding action then would be for this 


description of your sampling or review of 


those 450 boxes, and --


DR. ULSH: Are you looking for anything 


further on data integrity and safety concerns 


or are we --


MR. GRIFFON: I don’t think so at this 


point. 


MR. FITZGERALD: Not unless the work group 


directs because otherwise we’ve been through 


the review of what you dealt with the 5,000 


and I, you know, that’s the scope, and we’ve 


looked at it, and we’ve applied conclusions. 


MR. GRIFFON: Yeah, I don’t think we want 


any more action there. Taking a deep breath 


at that point. But the only, you know, other 


than the scope I think, and you may disagree 


with me, Brant, on this, but this question of 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

237 

the comparison of the logs versus the database 


still raises my concern as it applies to the 


coworker stuff that we’re going to run into. 


And so we’ve got several prongs that are 


pointing to this data completeness and 


coworker models. 


DR. ULSH: I hear your concern, Mark, but 


what I’m wondering is I haven’t looked at that 


particular section of SC&A’s report. I’m 


wondering if there are individual identifiers 


where we can see where the HIS-20 data, where 


Kathy couldn’t find it. If we can –-


Do we have that, Kathy? I mean, you 


know what you sent over so I mean do we have 


that kind of information in what you sent over 


already or is that something we need to 


request in addition? 


MS. DeMERS (by Telephone): I will send you 


a key. I don’t know if it’s available in what 


you got or not. 


DR. ULSH: So I mean we could take a look, 


Mark, and see whether or not --


MR. FITZGERALD: I suspect it is because of 


Price Anderson. I’m not sure what ended up, 


you know, in terms of identifiers. I doubt 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

238 

much went over with identifiers, so we’d have 


to get the key --


MR. GRIFFON: The Privacy Act. 


MR. FITZGERALD: -- provide a key that would 


cross walk. 


DR. ULSH: That would be helpful because 


we’ll take a look at that. 


MR. GRIFFON: And again, this number or one 


of the concluding statements here says 32 


percent were absent in the HIS-20 database. 


Now you may want to also look at CER since 


that’s the, your bioassay coworker models is 


based on CER so you may want to look at HIS-20 


and CER, right --


DR. ULSH: Okay. 


MR. GRIFFON: -- or primarily CER? I mean, 


I’m not, I’m more asking than telling. I 


think that’s what your coworker is based on, 


CER, right? 


DR. ULSH: The internal coworker data is 


based on CER data. 


DR. NETON: It’s got to be identified. 


DR. ULSH: Oh, that’s right, it is, isn’t 


it? 


MR. GRIFFON: It has to be identified. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 -- 

19 

20 

21 

22 

23 

24 

25 

239 

That’s the problem. That’s why I always have 


been doing mine in HIS-20, and the only time I 


can compare against CER is when I have these 


high values in certain time periods and they 


stand out. But these were not, if I 


understand SC&A’s report correctly, these 32 


percent absent from the HIS-20 were not only 


zeros or thinking that they were high values 


as well or mid-range values or whatever, it 


wasn’t just simply zeros. It was kind of all 


over the place. 


DR. ULSH: Keeping in mind that we only 


covered up to 1970, ’71, whatever. I have to 


look and see whether or not these were people 


who you wouldn’t expect to be there because 


they weren’t injured. When their employment 


terminated, I guess, is what’s going to be the 


MR. GRIFFON: Yeah. Well, that whole thing 


is troubling to me, too, that people were 


taken out and then some were put back in, and 


we don’t know who and what. 


DR. ULSH: Well, they weren’t, no, actually, 


we do know who it was. I mean, they weren’t 


taken out. They were never initially loaded. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

240 

The people who, I mean, this is described in 


the evaluation report. The people who 


terminated prior to that year, whatever it 


was, ’77, something like that, their data 


didn’t go into HIS-20 at all initially. Now 


later a subset of those were loaded back in if 


they were in that highest exposed workers that 


were part of the medical monitoring program. 


We know that. 


MR. GRIFFON: The highest exposed workers as 


defined by that later program, right? 


DR. ULSH: Right, that medical monitoring 


program. 


MR. GRIFFON: That was a semi-voluntary 


program though as well, right? 


DR. ULSH: Well, I suspect. I mean, they 


didn’t compel people to come in. 


MR. GRIFFON: Right, it was follow up. 


Okay, I think that, I think we need to, those 


reports we mentioned previously need to be reexamined and that very short Donna Cragle 


report has some interesting reading in it to 


compare. But let’s stay on schedule here, 


4:30. 


Is there any more on log book analysis 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

241 

specifically? 


DR. ULSH: No, I don’t think so. 


MS. DeMERS (by Telephone): No, not really. 


SUPER S (TIB 49)
 

MR. GRIFFON: Moving on to Super-S. Joyce, 


are you still with us? 


DR. LIPSZTEIN (by Telephone): Yes. 


MR. GRIFFON: Super-S, where do we stand, 


Joe and maybe Joyce can --


MR. FITZGERALD: Just generally, obviously, 


we presented back in June at the Board meeting 


in D.C. the review on the conceptual approach 


in OTIB-49, and I think certainly the 


conclusion at that point in time was that we 


thought that was scientifically valid. We 


have since proceeded to look -- at the 


direction of the work group –- look at the 


case model, the model cases that were 


included. Was it 25? Twenty-five model cases 


and Joyce has been evaluating those, and I 


think – am I right, Joyce, the only issue 


there was this lung adjustment factor? Are 


you making headway? 


MR. GRIFFON: Which now you have. 


MR. FITZGERALD: Which I think we got 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

242 

recently, but is that, have you concluded that 


that’s what you need to finish? 


DR. LIPSZTEIN (by Telephone): Yeah, what we 


got to see just the adjustment factor, but we 


still didn’t get everything because we got the 


adjustment factors that were used until ’95, 


and from ’95 on after ’95 we didn’t get what 


were the adjustment factors. 


MR. GRIFFON: Well, maybe you can follow up 


with Roger or Brant. 


DR. NETON: I thought we sent everything, 


but --


MR. FITZGERALD: It sounds like there’s, 


what, seven or eight years, just the tail end 


that’s missing. 


MR. GRIFFON: But I guess the outstanding 


action is for you to complete this review. 


MR. FITZGERALD: Complete the review --


MR. GRIFFON: This was the idea to see if 


the model cases selected were inclusive of the 


other 25. 


MR. FITZGERALD: Joyce, we’re going to 


pursue this with NIOSH, but I assume though 


that with the correction factor that you have, 


you can, in fact, pursue a large number of 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

243 

these? 


DR. LIPSZTEIN (by Telephone): Yes, yes. 


MR. FITZGERALD: Okay, so really just to 


make sure that we have for those individuals 


with data beyond ’95 you need that additional 


factor. 


DR. LIPSZTEIN (by Telephone): Yes. 


MR. FITZGERALD: Okay, so you’re in the 


process of going through those calculations 


now? 


DR. LIPSZTEIN (by Telephone): Yeah, and 


another point that is not only relevant to 


these 49, the high fired, if there was, if 


there is an adjustment factor, they have to be 


used on all claimants’ lung results. And they 


haven’t been from few claimants that were 


involved in the ’65 fire. 


DR. NETON: I don’t know that they were 


using --


MR. GRIFFON: I don’t think they relied on 


that data. 


DR. NETON: -- the lung analyses for dose 


reconstruction, Joyce. 


DR. LIPSZTEIN (by Telephone): I’m sorry? 


DR. NETON: We talked about that. We 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

244 

weren’t really planning on using the lung 


measurements --


MR. GRIFFON: For dose reconstruction. 


DR. NETON: -- the urinalysis was the 


primary method. Is that right? 


MR. SHARFI: Are you talking about the chest 


sample? 


DR. NETON: Yeah. 


MR. SHARFI: There’s been a little. I would 


not limit not using the chest sample. 


DR. NETON: Well, I didn’t say not use it, 


but I didn’t know that we were --


MR. GRIFFON: I thought it was discussed 


that the primary in this case for Rocky you 


were primarily looking at the urine, and you 


might use the lung to bound. 


DR. LIPSZTEIN (by Telephone): All 


claimants? No. If you have someone that with 


a lung cancer, and you have the lung counting, 


why would you use urine? 


MR. SHARFI: Yeah, I agree. I would not say 


we would not. 


DR. NETON: Well, I’m thinking about the 


Super-S issue here though. I mean, I don’t 


know. I need to think about this. At one 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

245 

point we had determined that we weren’t going 


to rely on the --


MR. SHARFI: On for like Hanford it’s more 


likely to use the urinalysis because it’s more 


sensitive, but and much lower MDA, but the 


Rocky Flats more often chest count that is 


more viable. 


DR. NETON: Yeah, but see that’s americium 


there, and if you’re talking about plutonium, 


you can’t see the broad side of a barn with a 


lung counter with plutonium. So I doubt that 


we would have hardly anyone with a measurable 


PU-239 burn. I mean, the detection limit’s 


somewhere around a couple hundred nanocuries, 


easily. 


MR. SHARFI: No, we’ve seen measurable 239 


in americiums in some of that Super-S 


materials so --


DR. NETON: Well, they’d have to be pretty 


large lung burdens. 


MR. SHARFI: Yes. Yes, these are big 


intakes. But the americium will be bounded in 


the matrix so it will exhibit the same type of 


biokinetics to the lung that you’re going to 


talk about plutonium too. 

1 

2 

3 

4 -- 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

246 

DR. NETON: Well, I don’t think that’s what 


we’re saying for the Super-S model. We can 


look at that. We’ll take that information and 


DR. LIPSZTEIN (by Telephone): And another 


thing that was raised actually by Bob 


Anigstein is that some people they were 


exposed to fire at Rocky Flats, and that these 


were not reported. And there was some fires 


in the glove box that were put out by the 


workers, resulted in this fire department 


being notified. 


And he said that sometimes those 


people they were monitored, but it was not 


recognized that they were exposed to high-


fired oxides. So when you calculate that 


dose, if the (unintelligible) is below the 


detection limit because it was high fired and 


we wouldn’t catch up in the beginning, and you 


don’t recognize it as high fire so you might 


be unfair to those workers. And I don’t 


really know how you would address this kind of 


exposure. 


DR. NETON: I thought our default assumption 


here, unless we can determine otherwise, was 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

247 

going to be high fired for virtually everyone 


that we couldn’t determine. 


DR. ULSH: Well, for lung cases. 


DR. NETON: For lung cases, right. 


DR. LIPSZTEIN (by Telephone): Yeah, and for 


systemic --


MR. SHARFI: It’d be one of the solubility 


choices that you would have to consider in all 


cases if you could not rule out that scenario 


by means of --


DR. NETON: You pick the most claimant 


favorable in any analysis. 


MR. SHARFI: Yeah, regardless of organ, so 


it wouldn’t be limited to the lung. It’d be 


all --


DR. LIPSZTEIN (by Telephone): But would you 


use high fired even if you did not know it was 


a high --


DR. NETON: Yeah, if it’s claimant 


favorable. 


DR. LIPSZTEIN (by Telephone): Okay, then 


that’s fair. 


DR. NETON: Because we recognize it. I 


think we determined it’s not just fires where 


high fired exists anymore. I mean, there are 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

248 

mechanisms to have high-fired plutonium 


without a fire. 


DR. LIPSZTEIN (by Telephone): Yes, that’s 


(unintelligible) be exposed to high-fired 


oxides without being exactly exposed to a 


fire. And the all these results would be 


below the detection limit and people would not 


have been (unintelligible) because either the 


(unintelligible) or they weren’t found -– 


well, for any reason they didn’t come up for 


the (unintelligible) but even though if you 


treat them not as high fired then it would be 


unfair, but --


DR. NETON: Right, we agree. I mean, we 


would use high fired. 


MR. GRIFFON: Well, the other case, and this 


came up actually from, I’m not sure it’s still 


related to Super-S, but it is sort of related 


to this inadvertent sort of unknown exposure 


question. And the reason it came up for me 


was reviewing these Health and Safety reports, 


and then I found that a lot of them were 


logging the high urine data points, and many 


of them were associated with wounds. 


And prior to this, so I tracked this 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

249 

back and found this Chapman document, a health 


physicist in the early years there, that was 


tracking some of this. And he raised a 


question, at least for me, that until the time 


of his paper, which I think was in the early 


to mid-‘60s, ’63, ’64, that they had no good 


method of wound monitoring. 


They came up with a method to monitor 


wounds, and he said prior to writing this 


paper he felt like that the biggest hazard for 


plutonium doses was inhalation. But he’s 


convinced now that it’s wounds. And I 


actually thought that prior to this that 


wounds would have been the exception rather 


than the rule. But apparently these were 


fairly common to get punctures in the glove 


box work and stuff. 


So my question would be if you had an 


acute exposure from an injection basically 


instead of an inhalation, is the chronic model 


going to be bounding? I know we’ve looked at 


acute inhalation spikes, and we’ve convinced 


ourselves always that the chronic is bounding. 


But in that situation --


MR. SHARFI: The dose associated with the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

250 

wound incident is usually much less because 


you get so much straight excretion to all you 


see in high peak in urine so quickly. 


MR. GRIFFON: But is that true for all 


organs is my question. I mean, certainly --


MR. SHARFI: Obviously, the lung is not 


impacted because it’s straight to blood. It’s 


going to bypass the --


DR. NETON: The organ dose is directly 


proportional to the --


MR. SHARFI: To the excretion. 


DR. NETON: -- the excretion, right? So you 


have a handle on that. 


MR. SHARFI: Correct. 


MR. GRIFFON: But if you have non-detect 


urine then the coworker chronic assumption 


should still be bounding? 


DR. NETON: I think so. I think --


MR. SHARFI: Usually inhalations almost 


always a more claim favorable assumption over 


wound incident because of the direct injection 


would cause a quick spike versus the long-term 


buildup of the, you have a much longer 


exposure scenario with a, inhalation takes 


time to get into the blood system or the --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

251 

DR. NETON: I don’t want to say too much 


without --


MR. GRIFFON: Yeah, I looked at this quickly 


and that’s why I’m asking because I’ve got to 


look at it further, too, but I wanted to raise 


it here so you could also consider that as 


another, and this is really on the 


implementation of the internal coworker. 


MR. SHARFI: And there is a wound TIB that 


covers how to assess wounds. 


MR. GRIFFON: Oh, I didn’t know that. 


DR. LIPSZTEIN (by Telephone): Yeah. 


DR. NETON: The NCRP model. 


MR. SHARFI: We have a, ORAU has a, there’s 


an OTIB, I can’t think of the number right 


now, but there’s one that does cover wound 


intakes. 


DR. LIPSZTEIN (by Telephone): Yes, and 


that’s to cover when you have the cancer of 


the lymph nodes. 


MR. GIBSON (by Telephone): This is Mike. 


Did I miss on the wound monitoring, did they 


actually use a wound, or did they use a 


bioassay sample after the fact of a wound? 


MR. GRIFFON: Well, I think they had a field 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

252 

technique to do both, yeah, both is the 


answer. 


MR. SHARFI: Yeah, there are reports inside 


the claimants’ files that had the wound 


counting data and then they also did a lot of 


full bioassay. 


MR. GRIFFON: But his report kind of says, 


you know, he wonders how many of these went 


undetected, and that sort of raised my 


question of whether, my question is not 


necessarily a wound TIB because the assumption 


is wounds happen. But we’re looking at the 


case where we didn’t know it was a wound. 


MR. SHARFI: If you want to look up the same 


bioassay result in an intake from an 


inhalation versus an intake versus a wound 


incident, I don’t know if the scenario where 


the inhalation does not give you a bigger dose 


than --


MR. GRIFFON: Okay, I got to run --


MR. SHARFI: You can use that wound TIB to 


run your scenarios and if you want to test 


that. 


MR. GRIFFON: Yeah, okay. I just wanted to 


raise it while we’re here so check it. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

253 

DR. LIPSZTEIN (by Telephone): If you assume 


there was an acute intake and knew there was a 


wound, and you take the bioassay data, and you 


go back and everything is okay. When there is 


no indication that there was a wound, so but ­

-


MR. GRIFFON: That’s why I questioned that. 


DR. LIPSZTEIN (by Telephone): -- all the, 


let’s say all results were below the 


detectable limits, and then acute inhalation 


intake and that will be very unfair to some 


because if you (unintelligible) it’s okay in a 


short time period, but if you take it for a 


long time period then it’s (unintelligible). 


MR. GRIFFON: Okay, maybe I can ask Joyce if 


you can look at that as well as Jim or Brant, 


whoever on your team wants to look at it. 


DR. LIPSZTEIN (by Telephone): I think one 


of the problems is that the wound model which 


is being done by NCRP, it’s almost ready, but 


it’s not ready yet. So you have the wound 


OTIB which is good for now, but it doesn’t 


cover everything that you have. If someone 


has a cancer of the lymphatic system, it’s not 


well covered by this wound OTIB. I think in a 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

254 

short time NCRP is going to publish a model 


for a wound and will solve everything. 


MR. GRIFFON: So let’s, it’s on our radar, 


and we’ll have SC&A and NIOSH look at that, 


but let’s move on to our last items. I know 


we’ll be done by 5:00. I know we will. 


NEUTRON ITEMS
 

Neutron issues, I’m going to need your 


help, Joe to kind of frame it, and maybe Ron 


can weigh in. 


MR. FITZGERALD: Yeah, this has been a 


longstanding discussion we’ve had. And I 


think there’s no one specific fundamental 


problem with the information that has been 


provided in terms of how neutron doses are 


being estimated, just that there were a number 


of pieces of data and information that we 


wanted clarified. And I think Brant itemized 


these very well in terms of five action items 


that I think the work group’s very familiar 


with. And frankly, at this stage, we’ve had 


Ron Buchanan working directly with ORAU to see 


if we can actually put this to bed because 


essentially it’s information that we need some 


clarifications, interpretations, corrections 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

255 

and it’s sort of a grab bag of different items 


which, I think at this point, we believe isn’t 


moving in an SEC direction, but we wanted to 


make sure of that fact. And that’s what we’re 


really looking to, from this discussion, to 


understand if that’s the case. So Ron, with 


that introduction, how does it look? 


MR. GRIFFON: And knowing that we all want 


to head for the airport. 


MR. BUCHANAN (by Telephone): Yeah, we’ve 


been going over this neutron issue and the 


main thing was two areas I wanted to look at 


is the proposed procedures, recommended 


procedures by NIOSH, claimant favorable and 


workable. They produce reasonable results for 


the doses assigned. And so that involved 


reviewing all the OTIBs and procedures and a 


lot of intertwined documents. And at this 


point, of course, and then we came along and 


we had OTIB-58 recently released a week or two 


ago which was a revision of the earlier one. 


My review to this shows that OTIB-58 


has made an effort to do a reasonable coworker 


dose model, and coupled with the NDERP report 


and OTIBs-50 and -52 and some others. And my 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

256 

take on it at this point is that I’m trying to 


clarify where some of the data came from 


that’s entered in the tables. 


I don’t necessarily have a problem 


with the procedures, and I don’t necessarily 


have a problem with the data. I just have not 


yet been to all 14, and I’m working with Matt 


and some of the others and Brant has forwarded 


some of the answers. I got those yesterday or 


the day before, and then I just opened the 


door and received the CD with six megabytes of 


neutron gamma data on it about an hour ago, 


and I haven’t had time to digest that. 


And so I know everybody’s wanting to 


close this meeting so what I, my bottom line 


is that at this point, that SC&A, the review 


of the recommended procedures indicates that 


there are no outstanding SEC issues at this 


point with our understanding of the 


recommended procedures. Now that hinges on 


the fact that the data put into these 


procedures is reliable and adequate. And I 


did not address all that issue as we spent 


most of the day on that. 


At this time I’m looking at the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

257 

procedures do they, are they claimant 


favorable, produce reasonable results, and at 


this time I do not see SEC issues with the 


recommended procedures and the data I’ve 


reviewed today. Now we haven’t completed that 


data accuracy and availability issue 


completely, but that’s where I stand on this 


point. 


MR. FITZGERALD: Which reflects what we 


talked about with the coworker model with 


different prongs we’re looking at. So he’s 


been on one prong we’ve been dealing with. 


MR. GRIFFON: We’re looking at the data 


issue on another prong which we spent a lot of 


time on. 


MR. FITZGERALD: So it sounds like really 


easy. The loose end is to look at the data 


behind the new tables and the new OTIB 


revision? 


MR. BUCHANAN (by Telephone): Well, actually 


there’s the tables, yes, there’s two 


additional tables in the OTIBs that I’m 


looking at and also the original tables which 


you didn’t have the data for before. So the 


four tables I’m looking at, plus there’s three 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

258 

additional tables for the construction workers 


which I have not touched on that aspect 


because I’m still trying to sort out the 


regular workers, and I’ll get to that after I 


understand the first tables. 


And so I have read the response of 


NIOSH on my questions, 14 questions I think, 


and I’m reviewing those. And I’m going to 


send another couple clarification questions to 


Matt here in the near future and also review 


the CD and make a decision whether I 


understand where all the data’s coming from, 


if it looks like it provides favorable 


results. 


MR. GRIFFON: And I would also request that 


if need be, you continue some of those 


technical calls on the neutron issue 


specifically. I mean, if you need a follow-up 


call --


MR. FITZGERALD: Yeah, we’re seeing how this 


goes and --


MR. GRIFFON: -- in the interim, right. 


MR. FITZGERALD: -- if it turns out that the 


disk and the additional information is 


sufficient, I think then we’ll just wrap it 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

259 

up. 


D AND D (TIB 0014)
 

MR. GRIFFON: Last but not least, the D&D 


worker question. 


MR. FITZGERALD: Yeah, I think we had some 


pretty productive calls on that. Certainly 


the information provided by Gene Potter in 


terms of looking at the top tier dose 


distribution versus the, I guess two sets 


really, all the subcontractors as well that 


were identified as the D&D subcontractors, 


demonstrated the dose distributions were 


equivalent and could be in fact enveloped by a 


common coworker model. I thought we were 


pretty satisfied and thought that kind of 


addressed the issue we were concerned about 


most. 


Really what’s left on that issue is 


the OTIB-14 extension of OTIB-38 which is this 


whole issue of what’s the coworker in it. If 


you buy into again that distribution, which we 


do, then how are you going to apply OTIB-38 to 


the D&D era. That’s what OTIB-14 is directed 


at. And there we spent some time looking at 


that, in particular --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

260 

Joyce, are you still on? 


DR. LIPSZTEIN (by Telephone): Yes, I am. 


MR. FITZGERALD: Okay, well, the only 


question that we come up with that is 


certainly workers were reviewed from the 


standpoint of fecal analysis, and some were 


reviewed on the basis of in vivo counts, and 


the OTIB isn’t very clear on how those would 


be accommodated within the model. And I think 


we just got, what, a few days ago, some 


additional information that Gene put together 


or somebody put together on that issue. 


Joyce, have you had a chance to -- I 


know it’s only been a day or two -- had a 


chance to look at that? 


DR. LIPSZTEIN (by Telephone): Yes, I looked 


at it, and now I’m going to analyze it. It’s 


basically said that most D&D workers were 


after ’95, and so we don’t have to worry too 


much about the required fecal samples, fecal 


samples from before ’95. So we just have to 


verify that, and I think now it looks like if 


it’s okay. 


MR. FITZGERALD: Yeah, this is a case where 


we looked at the concept, went to the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

261 

completeness of data, and now we’re looking at 


the application so in a way I think this will 


kind of sew up OTIB-38 and the D&D issue at 


the same time. 


MATRIX UPDATE
 

MR. GRIFFON: Now we come to the matrix. I 


want to walk through every item -- just 


kidding. I did want to bring up one specific 


thing on the matrix, item -- we did edit this 


matrix so I would ask maybe the work group and 


all others to read through these final 


actions. And I left, I usually try to track 


actions so there should be a little chronology 


in most of these, and Brant reviewed this as 


well as Joe and Emily apparently so we have 


this redacted version. 


But I wanted to point out on item 18, 


this is one place where I put a note that it 


seems like one of these that we might have 


just kind of forgotten a little bit, or it was 


inconclusive and I didn’t know if we needed to 


take this any further. 


Brant, maybe you can give us some 


background on this one. 


DR. ULSH: Yeah, Joe and I talked about 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

262 

this, Mark, because I noticed that while the 


phrase that caught my eye was closure not 


achieved. And this goes back to what we call 


detailing analysis, and it was related to the 


concern that was expressed by the petitioners 


that sometimes workers would leave their 


badges in their locker and wouldn’t wear them 


at the radiation area. 


And so it was suggested, and we did 


some preliminary analyses to look at whether 


or not you see evidence of tailing off of dose 


that would indicate that the rate at which a 


worker accumulates dose or at least that’s 


reflected on his badge, tails off. Now we did 


some preliminary analyses and presented that 


to SC&A, and it was our conclusion that we 


didn’t really see evidence of that. 


And I think SC&A concurred with that; 


however, they also said that they noted that 


the sample size was small. And it was. The 


reason we didn’t keep going with that -- I 


think we discussed it at a working group 


meeting -- was that it wasn’t clear to us that 


that would really give us a definitive answer 


to the question. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

263 

MR. GRIFFON: I do remember that. 


DR. ULSH: Because it wouldn’t tell you 


whether or not the worker was actually pulled 


out of the area or whether his badge was only 


pulled out of the area. So we decided, I 


think as a group, to pursue this on some of 


these other prongs in terms of the safety 


concerns and the data integrity. 


Does that pretty much summarize, Joe? 


MR. FITZGERALD: Yeah, I think that’s kind 


of where we left it although I agree that was 


kind of, you know, that prong was left, and we 


went, pursued it elsewhere. So it was sort of 


a loose end, but I don’t disagree with that 


conclusion. We went as far as we thought was 


useful to go through, and this was maybe a 


less perfect way of reaching that conclusion. 


We don’t disagree with the analysis at the 


time. 


Ron, do you want to add anything? 


MR. BUCHANAN (by Telephone): No, not 


particularly. We agreed with what was stated 


by NIOSH. It’s just that we didn’t feel that 


you could take those few cases and extrapolate 


into all the years to all the workers. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

264 

MR. GRIFFON: So my question sort of is do 


we in our other prongs get at this question. 


I guess we attempted to. Did we? 


MR. FITZGERALD: We attempted to. I mean, 


certainly in the work that Kathy did trying to 


run these individual situations where there 


were some allegations about workers not 


wearing badges and what have you. I think we 


looked at that certainly on the completeness 


side. It’s kind of a, you know, how many 


prongs do you need in order to put something 


like that to bed? I don’t know. That’s kind 


of a judgment call. 


MR. GRIFFON: And there seem to be ways to 


possibly get at it. I don’t know if we’ve 


explored all of them, but if there’s people 


that are, you know, if you scan through the 


annual summary data, and you see people near 


the limits, if we have their files already 


pulled, you know, you might look at if there 


was any indication, I mean, I see log book 


indications that people were pulled from 


areas. It certainly looked like restrictions 


were applied especially on the internal side. 


I saw notices of that. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

265 

DR. ULSH: Yeah, and sometimes you’ll see in 


the worker RAD files memos that say that there 


are work restrictions. I don’t, it’s nothing 


I’ve looked for systematically, but I have 


seen examples of that. 


MR. GRIFFON: So I don’t know, this was 


derived from an individual allegation? Is 


that correct? 


MR. FITZGERALD: Yeah, it was actually 


affidavit issues as well as some of the worker 


input, but --


MR. GRIFFON: You mean did they give us 


specifics of individuals where it happened? 


MR. FITZGERALD: No. 


MR. GRIFFON: No, they just kind of said 


they thought this practice --


MR. FITZGERALD: Right. 


MR. GRIFFON: And we haven’t seen any --


MR. FITZGERALD: Not in terms of running it 


down from safety concerns and data integrity. 


DR. ULSH: And this is on the overarching 


issues list. This particular issue. 


MR. GRIFFON: Right. 


MS. MUNN: Well, and the other side of that 


coin actually is how many workers would have 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

266 

been expected to be included in a group that 


would have done this. 


MR. GRIFFON: Right, how much will that 


affect the overall class. 


MS. MUNN: Exactly, exactly. 


DR. ULSH: In fact, Wanda, that prods my 


memory. I did talk about this issue in 


evaluation for a presentation in April. 


MS. MUNN: I think you did, uh-huh. I think 


we did go over this. 


MR. GRIFFON: And if we had heard, I don’t 


know that we heard many, many people saying, 


yeah, this happened all the time. I don’t 


think that’s the --


MR. FITZGERALD: We didn’t find evidence of 


a systemic issue. 


MR. GRIFFON: So I don’t know there’s any 


further action we can do here other than that 


in the matrix I’ll note that we tried to pick 


this up and cover this in the individual RAD 


file reviews and data completeness and other 


prongs as we’re describing. 


MS. MUNN: At the time I read this, I saw 


the further discussion by the work group. My 


instant reaction was, why? I thought we had 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

267 

talked about it already. 


MR. GRIFFON: That was the only, I think we 


were in agreement on the matrix otherwise. 


DR. MAKHIJANI: The main issue that’s come 


up in this kind of regard was, you know, the 


going up the zeros in ’69 and so on, and we 


know there was another explanation for that. 


There was a policy for not reading badges and 


so on. And we tracked that in a different 


direction. It did not have the same 


explanation as that item 18. 


MR. GRIFFON: But I also think Wanda’s 


statement’s important in this regard that 


we’ve got to consider how much the class could 


have been affected if this happened a little, 


a few times or whatever. 


MR. FITZGERALD: Well, I think you had to do 


a reconnaissance review just to see whether it 


had any corroborating evidence. We didn’t 


find any, but certainly we wanted to take it 


seriously and pursued it but didn’t find 


anything. 


MR. GRIFFON: I think that’s it on our 


agenda. I would ask if anyone on the phone 


has any final thoughts. I know it’s getting 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

268 

kind of late in the day, but especially the 


interested parties from the congressional 


staff. Any comments? 


UNIDENTIFIED: Could someone keep us posted 


when that report comes out that was referenced 


in the last working group call? 


MR. GRIFFON: We will. I think we committed 


already to any reports that, from here on out, 


that once they’re through Privacy Act review 


and approved for distribution, we’ll get those 


to you ASAP so NIOSH has that out there on 


their agenda, and we’ll do that for sure. 


UNIDENTIFIED: Thank you very much. 


MR. GRIFFON: Thank you for staying with us 


all day. 


DR. MAKHIJANI: Mark, is there a scheduling 


question about wrapping things up that we --


MR. GRIFFON: Yeah, I guess, I was looking 


at the calendar, and we now have until May, 


but if we walk that backwards, I think we 


really want to get something to the 


petitioners and the interested parties by the 


end of March, first of April. That gives 


everybody 30 days or so. I think the 


meeting’s in early May if I have my dates 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

269 

right, yeah. So given that I don’t know. It 


seems to me that any responses from NIOSH 


would be helpful if you had them by, what, the 


end of February? 


MR. FITZGERALD: Yes. 


MR. GRIFFON: Do you think that’s, I think 


data completeness is probably the big --


DR. ULSH: Let’s start with that, the ’69 


section and the data completeness section. 


MR. GRIFFON: Let’s try for that. I mean, 


we’re all working toward the same goal here, 


same end date. And we also have to keep in 


mind that any final product from anyone has to 


go through Emily’s review. So that’s going to 


maybe slow us down a little bit, but I know 


they’ll turn around things quickly. 


MR. FITZGERALD: Well, we’re hoping to get 


as many sections cleared beforehand. 


MS. MUNN: So are we going to talk about 


this, are we going to set another meeting 


date? 


MR. GRIFFON: Well, we have the Board 


meeting coming up. I thought maybe we’ll, if 


you want to look at calendars now --


MS. MUNN: No, I was thinking about, this is 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

270 

not going to be, what we’ve been talking about 


here today is certainly not going to be ready 


at the Board meeting. 


MR. GRIFFON: Right. 


MS. MUNN: And so --


MR. GRIFFON: We’re going to have to have 


something beyond that, but I was going to wait 


and kind of check in with you guys in 


Cincinnati at the Board meeting and then say, 


okay, let’s look at our calendars to see what 


makes sense between February 7th and the next, 


our next milestone, the end of February I 


guess. 


DR. ULSH: Probably not February 7th . 


MR. GRIFFON: Probably like the third week 


in February we’ll meet. 


MS. MUNN: Maybe we could do the first week 


of March. Wouldn’t that give us --


MR. FITZGERALD: That’d be a little tight. 


See, I’m a little concerned that we have to 


both accommodate any final changes and go 


through final tech editing which we didn’t do 


on this one, which we’re finding all kinds of 


glitches. And then certainly make it 


available to NIOSH for final Privacy Act 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

271 

review so that can then go to the outside 


world. And the logistics I think we need most 


of March for is my guess by the time it’s all 


done. 


MR. GRIFFON: Yeah, I think the third week 


in February, although I’m not really ready to 


pick a date. I apologize because I know 


there’s the Savannah River classified meeting 


that I have to be at somewhere in that third 


week in February. I think it’s the 20th and 


21st, but we haven’t pinned it down. But I’m 


thinking the third week in February. That way 


if there’s any -- does that make sense? 


MR. FITZGERALD: Yeah, I think that --


MR. GRIFFON: The final changes by any final 


things by NIOSH then everything, you know, 


we’re shooting for that end of February, early 


March. And that’ll give you guys a month to 


try and get something out for full 


distribution to everyone, right? 


MR. FITZGERALD: We’re kind of looking at 


maybe a couple weeks to get it to NIOSH so 


they have a couple weeks to then make 


distribution. So I think, really, we’re only 


talking a couple weeks from our side, 

1 

2 

3 

4 -- 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

272 

hopefully. 


MR. GRIFFON: Well, let’s look at the third 


week in February tentatively, maybe toward the 


DR. MAKHIJANI: Maybe the end of February? 


DR. ULSH: The third week of February for 


another working group meeting? 


MR. GRIFFON: Yeah. 


DR. ULSH: End of February for whatever 


responses we’re going to provide. Is that 


what you’re --


MR. GRIFFON: Yeah, yeah. 


DR. MAKHIJANI: Well, if there’s going to be 


a working group meeting, presumably since most 


of the action items, I think, are in NIOSH’s 


court at this time, maybe we should have 


something from NIOSH so we can actually 


discuss it. 


MR. GRIFFON: Well, that was the, yeah --


DR. MAKHIJANI: Well, I don’t know. 


MR. GRIFFON: -- I mean, I don’t know if 


it’s worth meeting if, you know, until we have 


these products so that’s the question. Maybe 


we should just do it the last week in February 


and then you have your sort of almost final, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

273 

near final product. 


MS. MUNN: We’re still planning for the 


first week of March. 


MR. GRIFFON: I would also say as you --


Brant, you’ve been doing this very well as you 


complete things certainly get them around to 


us as you can. 


DR. ULSH: Will do. 


MR. GRIFFON: That’s it, right? Anything 


else? 


 (no response) 


MR. GRIFFON: Meeting adjourned. 


(Whereupon, the working group meeting 


concluded at 5:03 p.m.) 

______________________________ 

274 

1 CERTIFICATE OF COURT REPORTER 


STATE OF GEORGIA 


COUNTY OF FULTON 


 I, Steven Ray Green, Certified Merit Court 


Reporter, do hereby certify that I reported the 


above and foregoing on the day of January 26, 


2007; and it is a true and accurate transcript 


of the testimony captioned herein. 


 I further certify that I am neither kin 


nor counsel to any of the parties herein, nor 


have any interest in the cause named herein. 


 WITNESS my hand and official seal this the 


26th day of February, 2007. 


STEVEN RAY GREEN, CCR 


CERTIFIED MERIT COURT REPORTER 


CERTIFICATE NUMBER: A-2102